Search - considered
Results 15071 - 15080 of 49188 for considered
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. ...
Technical Interpretation - External
13 June 2016 External T.I. 2015-0620371E5 - Clergy Deduction - Aboriginal Spiritual Caregivers
More specifically you ask if an ASC would be considered “a regular minister of a religious denomination” who ministers to “a diocese, parish or congregation”, as those terms are used in the Act. ... In this respect, you have asked whether ASCs are considered to be ministering to a congregation. ... Chaplains in hospitals, jails, the armed forces and other such organizations are generally considered to minister to congregations.” ...
Technical Interpretation - Internal
27 June 2011 Internal T.I. 2011-0404771I7 - Clergy Residence Deduction
Reasons: The group of children attending the children's ministry is considered to be a congregation. The Taxpayer being a pastor for this ministry, is considered to be 'in charge of or ministering to' the congregation. Further, the children's ministry is considered a specialized ministry based on the explanation in paragraph 16 of IT-141R. ...
Technical Interpretation - External
26 October 2010 External T.I. 2011-0419221E5 - Employer-Provided Vehicle
You have not indicated whether the employees are permitted to use the vehicles for personal travel other than from home to work and back or whether the vehicles are considered to be "automobiles" for income tax purposes. ... However, where the employee proceeds directly from home to a point of call other than the employer's place of business to which the employee regularly reports or returns home from such a point, the use of the vehicle is considered employment-related. ... The CRA generally accepts that the employment benefit arising from the personal use of the motor vehicle that is not an automobile will be considered reasonable if it is calculated based on the rates prescribed in section 7306 of the Income Tax Regulations. ...
Conference
8 June 2010 Roundtable, 2010-0362321C6 - Estate Refreeze Transaction
Question (a) Provide examples of transactions that might be considered to be the stripping of corporate assets. ... (a) Could you please provide some further guidance with respect to what transactions might be considered to be the stripping of corporate assets. ... Furthermore, in cases where the refreeze transaction is not implemented on a FMV basis, the application of subsection 51(2), 86(2) or paragraph 85(1)(e.2) would also have to be considered. ...
Technical Interpretation - External
14 March 2011 External T.I. 2010-0386121E5 - Deductibility of soft cost
In which period an expense is considered to have been incurred, is a question of fact. ... Specifically, you would like to know if subsection 18(3.1) is applicable to costs incurred in a situation where a land developer, after the acquisition of land, finds that the land cannot be developed any further or is considered worthless. ... Paragraph 8 of Interpretation Bulletin IT-153R3, entitled 'Land Developers- Subdivision and Development Costs and Carrying Charges on Land', states that "site development is considered to begin with the installation of services" and further states "where serviced lots are acquired site development is considered to begin at the earlier of the date the taxpayer starts to install further services to the lots or the date he starts to pour footings". ...