Search - considered

You have asked if the editing and printing activities are considered to qualify as M&P activities for purposes of the M&P credit. ... In paragraph 41 of IT-145R (Consolidated)- Canadian Manufacturing and Processing Profits – Reduced Rate of Corporate Tax (Cancelled), the CRA has indicated that, "The activities connected with the processing of film into prints and slides, negatives into prints and the enlarging of prints are considered to be qualified activities. ... Accordingly, based on the comments in IT-145R, if the taxpayer's business is considered to be the rendering services as opposed to selling goods, the activities would not qualify as M&P activities. ...

Generally, fundraising, by its very nature, is considered a profit activity. ... It is always a question of fact whether fundraisers are carrying on a business or if amounts received can be considered gifts. ... In many cases, the amounts received would be considered gifts. If the amounts are gifts then it is our view that the fundraisers would not be subject to tax on the income. ...

Hence the deceased is not considered in the determination of a "resident contributor". ... Accordingly, the Estate will be considered to be a contributor to the Trust. ... Therefore, in the given instance, the deceased is also considered to be a contributor to the Trust. ...

If such an addition or improvement vests in the owner of the building, a benefit is considered to have been conferred on the shareholder by the corporation pursuant to subsection 15(1). The amount of the benefit is considered to be the present value of the amount, if any, by which the addition or improvement increases the value of the building to the shareholder at the time the building reverts to the shareholder. ... The benefit considered to be conferred in a particular taxation year is based upon the portion of the addition or improvement completed during that year. ...

15 August 2012 External T.I. 2012-0457311E5- Deemed Non-Resident CRA Tags 250(5) Principal Issues: Whether or not an individual is considered to be a deemed non-resident of Canada. ... We have insufficient details to undertake a complete review of all of the factors which must be considered in making a residency determination based on the treaty tie breaker rules. ... Conclusion An individual, that is a factual resident of Canada and a resident of a country with which Canada has a tax treaty, may be considered a deemed non-resident of Canada by virtue of subsection 250(5) of the Act. ...

Whether a gain arising on the sale of land will be considered to be on account of income or a capital gain, or a combination of both, involve questions of fact that can be determined only after reviewing all the relevant facts in a particular situation. ... However, the various factors the courts have considered in making such determinations are also set out in this paragraph and, as also noted therein; while no one factor is conclusive the taxpayer's motivation in obtaining the property is usually a significant factor. ... As stated in paragraph 12 thereof, vacant land used by its owner for the purpose of gaining or producing income (capital property) will be considered to have been converted to inventory at its fair market value at the time when the owner commences or causes the commencement of improvements to the property with a view to selling it. ...

Yes, would likely be considered income from property. Reasons: 1. Could indicate a profit purpose. 2. If business income, would likely indicate a profit purpose organization and would not be considered an NPO. ... Where an organization does not meet these conditions, the organization would no longer qualify for the tax exemption provided for in paragraph 149(1)(l) and would therefore be considered a taxable organization. ...

Specifically, you asked the Income Tax Rulings Directorate to provide guidance on the factors considered in making such a determination. ... The ordinary meaning of this term has been considered in Canadian domestic case law. In particular, Canadian courts considered the meaning of the term "substantial" in (SCC) Manning Timber Products Ltd. v MNR [52 DTC 1148]. ...

However, a depreciable property is not considered to have been acquired until a capital cost has been incurred in respect of that property. ... As per paragraph 9, a lessee is considered to have disposed of a leasehold interest at the time of an assignment of the lease or to have a partial disposition when the lease is sublet. ... The tenant is considered to have relinquished a right or rights in respect of a leasehold interest, and thus such an amount represents proceeds of disposition of part or all of the leasehold interest. ...

Position: Generally yes Reasons: An individual cannot be considered an eligible individual for a particular month until they meet the eligibility criteria for being an eligible individual in that month, and apply for the CCTB for that month. An individual cannot be considered to be an eligible individual at the beginning of a month, unless they have filed the prescribed forms and prescribed information within 11 months of the end of that month. ... An individual cannot be considered an eligible individual for a particular month until they meet the eligibility criteria for being an eligible individual in that month, and apply for the CCTB for that month. ...