Search - considered

In terms of whether an individual is considered a qualifying student, such a determination must be made on a monthly basis and is always a question of fact. ... In these instances, the grant recipients would not be considered to be qualifying students. ... Assuming that the SEP meets the 12-hour requirement, the student in this case will likely be considered a PT qualifying student in respect of the study-abroad program. ...

19 August 2013 Internal T.I. 2013-0490901I7- medical expense tax credit CRA Tags 118.2 (3)(b) Principal Issues: Is the refundable Ontario Healthy Homes Renovation Tax Credit (OHHRTC) considered an amount that a taxpayer is "entitled to be reimbursed" for the purposes of paragraph 118.2(3)(b) of the Income Tax Act (the "Act")? ... Upon review, we have concluded that the OHHRTC will not be considered to be a reimbursement for the purpose of paragraph 118.2(3)(b) of the Act. ...

Entities that are subject to tax, but with respect to which tax may be relieved under an integrated system, are not considered "fiscally transparent". ... A trust that is not disregarded for Canadian tax purposes would generally not be considered to be an entity that is "fiscally transparent". ...

19 May 2006 External T.I. 2006-0172051E5- Shareholder Manager Remuneration Unedited CRA Tags 67 Principal Issues: Whether a bonus paid to the principal shareholder of a holding company from the proceeds of disposition of shares in an operating company would be considered a reasonable expense of the holding company under the CRA's policy on the reasonableness of shareholder/manager remuneration? ... Specifically, you asked whether a bonus paid to the principal shareholder of a holding company from the proceeds of disposition of shares in an operating company, would be considered a reasonable expense of the holding company under the CRA's policy on the reasonableness of shareholder/manager remuneration, which is discussed in Income Tax Technical News Nos. 22 and 30. ...

Principal Issues: Is vacation pay or banked sick leave considered a bonus for purposes of the Act? ... We confirm, as expressed in our letter dated June 3, 1998 and our telephone conversation of June 23, 1998 (XXXXXXXXXX/Sarazin), that vacation pay and sick credits will not be considered a bonus for the purposes of proposed subsection 100(3.2) of the Regulations. ...

Position: Yes Reasons: All permanent establishments in Canada of a corporation are considered to be in a province. 971855 XXXXXXXXXX Michèle Trotier Attention: XXXXXXXXXX July 11, 1997 Dear Sirs: Re: Reference No. 951622 Single Purpose Corporation- Large Corporation Tax This is a follow-up to a recent telephone conversation between Michèle Trotier of our Directorate and XXXXXXXXXX of your firm enquiring about the Part 1.3 tax implications with respect to a single purpose corporation. ... We would note that in determining an amount under Part IV of the Income Tax Regulations for purposes of item B of the formula in section 8601 of the Income Tax Regulations all permanent establishments in Canada of a corporation are considered to be in a province. ...

You have asked that we confirm that where a retired partner has an income interest in a partnership pursuant to subsection 96(1.1) of the Act, that interest can be considered "inventory" and therefore eligible for "rollover" treatment, pursuant to subsection 97(2) of the Act, upon readmission to the partnership. ... It is therefore our conclusion that the subsection 96(1.1) of the Act continuing income interest in a partnership cannot be considered inventory for purposes of subsection 97(2) of the Act. ...

Our Comments It is the Department’s view that the cost of perennial plants, orchard trees and nut trees purchased would, on the initial establishment of an orchard, be considered to be capital expenditures that would be added to the cost of farmland. The cost of replacement plants and trees would be considered deductible expenses. ...

Position: no. not considered inventory Reasons: Reading of the law. XXXXXXXXXX 981290 S. Tevlin Attention: XXXXXXXXXX July 29, 1998 Dear Sirs: Re: Subsection 97(2) of the Income Tax Act We are writing in response to your letter dated May 13, 1998 wherein you asked that we reconsider the position, as described in our letter 980186 dated February 10, 1998, that a subsection 96(1.1) “right” is not to be considered inventory to a retired partner. ...

Principal Issues: Is vacation pay or banked sick leave considered a bonus for purposes of the Act? ... We confirm, as expressed in our letter dated June 3, 1998 and our telephone conversation of June 23, 1998 (XXXXXXXXXX/Sarazin), that vacation pay and sick credits will not be considered a bonus for the purposes of proposed subsection 100(3.2) of the Regulations. ...