Search - considered

Results 13681 - 13690 of 49392 for considered

Montreal (City) v. Old Port of Montréal Corporation Inc., 2021 FC 806

It appears that, prior to 2014, the City and the OPMC applied the agreement that had been reached by the parties as to which areas should or should not be considered “urban park” not subject to PILTs. ... The City does, however, submit that the Bonsecours Basin Pavilion, including buildings 4 (the Terrasse Bonsecours) and 5 (the Chalet Bonsecours), must be considered federal property in light of its commercial and independent function as a restaurant. ... Fruits and other products of the soil may be considered to be movables, however, when they are the object of an act of disposition. 900. ...

Canada (National Revenue) v. Shopify Inc., 2025 FC 969

In the present case, the parties have agreed that the draft requirement contains twenty-one separate items, each of which must be duly considered in the Court’s ultimate determination. ... PayPal, Bambora, Helcim). b) The Feasibility and Proportionality of the Proposed UPR [262] In Rona FC, PayPal, and Bambora, this Court considered the feasibility of a UPR request within the exercise of its discretion. ... In a fact-driven, evidence-based process, the parties in this case have presented relevant evidence and arguments on the broad proportionality of the Proposed UPR, and the Court has accordingly considered it. ...

9 November 1989 Ruling 58821 F - Acknowledgement

9 November 1989 Ruling 58821 F- Acknowledgement Unedited CRA Tags n/a 19(1) File No. 5-8821 Bob O'Bryne (613) 957-8821 November 9, 1989 Dear Sirs: 24(1) This will acknowledge your letter of October 4, 1989 in which you provided a brief summary of some of the facts which you think should be considered when reviewing the 24(1) case. The contents of your letter will be considered as part of our review of this case. ...

9 November 1989 Income Tax Severed Letter AC58821 - Acknowledgement

9 November 1989 Income Tax Severed Letter AC58821- Acknowledgement 5-8821 R.C. 0'Bryne (613) 957-8821 19(1) NOV- 9 1989 Dear Sirs: 24(1) This will acknowledge your letter of October 4, 1989 in which you provided a brief summary of some of the facts which you think should be considered when reviewing the 24(1) case. The contents of your letter will be considered as part of our review of this case. ...

16 May 2012 External T.I. 2012-0438241E5 - Retired Partner Income

16 May 2012 External T.I. 2012-0438241E5- Retired Partner Income Unedited CRA Tags 96(1), (1.1), (1.6); 123.4; 125; 129 Principal Issues: Whether income received by a corporation who ceased to be a member of a partnership in accordance with subsection 96(1.1) of the Income Tax Act (the "Act") can be considered "specified partnership income" or "aggregate investment income" under subsection 125(7) or 129(4) of the Act, respectively. ... XXXXXXXXXX 2012-043824 André Gallant May 16, 2012 Dear XXXXXXXXXX: Re: Retired Partner Income We are writing in reply to your correspondence dated February 27, 2012, wherein you enquire whether income received by a corporation that ceased to be a member of a partnership in accordance with subsection 96(1.1) of the Income Tax Act (the “Act”) can be considered “specified partnership income” or “aggregate investment income” under subsection 125(7) or 129(4) of the Act, respectively. ... In our view, the income received by the retired corporate partner in your hypothetical situation would not be considered to be “specified partnership income” or “aggregate investment income” under subsection 125(7) or 129(4) of the Act, respectively. ...

14 December 2009 Ministerial Correspondence 2009-0343051M4 - TFSA and Superficial Loss

Reasons: A taxpayer's TFSA trust is considered an affiliated person with the taxpayer. ... Under the Income Tax Act, a taxpayer's TFSA trust is considered a person affiliated with the taxpayer. ... " Accordingly, a capital loss realized from securities sold by a taxpayer and then immediately repurchased by the taxpayer's TFSA trust would be considered a superficial loss, and the amount of the capital loss would be nil. ...

7 January 2011 External T.I. 2009-0330971E5 - TFSA Withdrawal Fee

7 January 2011 External T.I. 2009-0330971E5- TFSA Withdrawal Fee Unedited CRA Tags 146.2(1) Principal Issues: Whether a withdrawal fee charged to a TFSA arrangement per withdrawal transaction will be considered a distribution as defined in subsection 146.2(1)? ... Tsang January 7, 2011 Dear XXXXXXXXXX: Re: TFSA Withdrawal Fee This is in response to your letter of February 27, 2009, wherein you requested our comments on whether a Tax-free Savings Account ("TFSA") withdrawal fee would be considered a "distribution" as defined in subsection 146.2(1) of the Income Tax Act (the "Act"). ... Where a fee is charged for withdrawing funds from a TFSA, this fee is considered a cost to the TFSA and should be paid with funds held within the TFSA. ...

29 November 2016 CTF Roundtable Q. 3, 2016-0670201C6 - Agnico-Eagle Mines Decision

If we apply the methodology provided by the FCA, it would appear that an issuer of debentures could be considered to have realized a loss. Does the CRA agree that an issuer could be considered to realize a loss on the conversion and, if so, that the loss is a loss described in subsection 39(2) or an otherwise deductible capital loss? ... Additionally, although not raised in Agnico-Eagle, the potential application of subsection 143.3(3) of the Act to the computation of any gain or loss arising on a conversion of a debenture should be considered in any similar fact situation, and could impact the application of the methodology endorsed by the FCA. ...

3 April 2008 Ministerial Correspondence 2008-0266981M4 - Fitness Tax Credit

Reasons: To be considered ongoing, the Regulations specify a minimum duration of eight weeks. ... " The Income Tax Regulations define what is considered a "prescribed program of physical activity" for the purposes of the credit. ... To be considered ongoing, the Regulations specify a minimum duration of eight weeks, with a minimum of one session per week, substantially all of which includes a significant amount of physical activity. ...

22 April 2008 External T.I. 2007-0245171E5 - Computation of income

The Queen (2002 SCC 46) that "where the nature of a taxpayer's venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act. ... In your situation, if you think that not all relevant factors were considered or that circumstances have changed, you should contact the Client Assistance Division of your local TSO. ...

You are here