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Results 15071 - 15080 of 49195 for considered
TCC
Société en commandite Sigma-Lamaque v. The Queen, 2010 TCC 415
Dallaire considered the application of section 182 of the ETA whereby a tax is deemed to be paid when an amount is paid following the breach of a contract. ... This is purely the interpretation of the appellant who, in performing certain calculations, considered that this could be the case. ... Moreover, it seems as if the fees, expenses and costs incurred by Caterpillar to exercise its rights under the lease and all of the charges related to the late payments were considered separately under the heading "Repossession Costs" (Exhibit A-1, tab 4, page 142) ...
TCC
Charlebois v. The King, 2025 TCC 76 (Informal Procedure)
The King, 2023 TCC 55, at para 50. [14] In considering a person’s intention through a lens of occupancy, this Court has considered several factors, including the following in Sozio v. ... Having considered the appellant’s oral testimony and the documentary evidence, I find myself unable to accept the appellant’s evidence. ... He might have moved a mattress and slept there on a few occasions, but I am unable to accept that the appellant occupied the property within the meaning of that concept as considered in the case law referred to above. ...
Technical Interpretation - Internal
13 April 1995 Internal T.I. 94133770 - Reclamation and clean-up costs
The factors are derived from those considered by the Supreme Court of Canada in Johns-Manville Canada Inc. v. ... On balance, expenditures that are a capital cost of equipment, facilities and structures for XXXXXXXXXX will be considered capital. ... Costs incurred to XXXXXXXXXX are appropriately considered to fit into two categories; costs to XXXXXXXXXX. ...
Technical Interpretation - Internal
13 April 1995 Internal T.I. 9413377 - Reclamation and clean-up costs
The factors are derived from those considered by the Supreme Court of Canada in Johns-Manville Canada Inc. v. ... On balance, expenditures that are a capital cost of equipment, facilities and structures for XXXXXXXXXX will be considered capital. ... Costs incurred to XXXXXXXXXX are appropriately considered to fit into two categories; costs to XXXXXXXXXX. ...
Technical Interpretation - Internal
4 July 2002 Internal T.I. 2002-0148217 - Foreign Tax Credit, U.S. Partnership
Principal Issues: Is US tax paid by a Canadian-resident individual with respect to his limited partnership interest in a US limited partnership that carries on business in the US considered non-business-income tax and deductible under s.20(12) of the Income Tax Act ("ITA")? Position: No Reasons: Assuming that the US limited partnership is considered to be a partnership for Canadian tax purposes, all partners, including the limited partner, is considered to carry on the business of the partnership. ... Since the US partnership is earning business income, X is considered to be earning US business income.? ...
Technical Interpretation - External
23 January 2014 External T.I. 2012-0467711E5 - Clergy Residence Deduction
Generally, financial self-sacrifice or denial of material comfort is considered to exist where a member's pay scale is substantially less than that of an employee performing similar duties in a non-religious organization. ... Based on the information provided, the Organization does not appear to embody the 2nd, 3rd, 4th, or 5th characteristic, and would not be considered a religious order. Consequently, the Employee would not be considered a member of a religious order. ...
Technical Interpretation - External
22 October 2013 External T.I. 2013-0492901E5 - Motor vehicle - allowances & expenses
In the current situation described, the amount paid to the employee would not be considered a reimbursement because it is not for a specific expense incurred by the employee. ... An employee who reports to work at a particular site for an extended period of time will likely be considered to regularly report to work at such location. ... As well, travel directly from one work location to another work location is considered to be employment-related travel. ...
Technical Interpretation - Internal
5 November 2013 Internal T.I. 2013-0494611I7 - Religious order
More specifically, you have asked for guidance in determining whether XXXXXXXXXX (Organization) would be considered a religious order for purposes of paragraph 8(1)(c) of the Income Tax Act (Act). ... It is our view that the 6th characteristic needs to be considered, but would not be the deciding factor in determining whether an organization is a religious order. ... Therefore the Organization would not be considered to be a religious order. ...
Technical Interpretation - External
24 September 2012 External T.I. 2012-0461521E5 - Adoption in fact and extended meaning of child
In your letter, you are inquiring whether a particular individual would be considered your adopted child on the basis of an “adoption in fact”. ... It is possible in certain circumstances that a person might be considered wholly dependent notwithstanding that he or she had income. ... A person may be considered the child of an individual under the extended meaning of child found in the Income Tax Act. ...
Technical Interpretation - External
17 January 2013 External T.I. 2012-0468321E5 - Capital gain on sale of land
Generally, a real or immovable property is considered to be used principally in a farming business by an individual if its primary use (that is, more than 50% of its use) is in the operation of a farming business. ... Some of the criteria to be considered in making this determination are set out in paragraph 4 of Interpretation Bulletin IT-322, Farm Losses. However, as indicated in paragraph 9 of Interpretation Bulletin IT-433R, Farming or Fishing- Use of Cash Method, the crop share received by a landlord in a sharecropping arrangement is generally considered to be rental income and not income from farming. ...