Search - considered
Results 161 - 170 of 49220 for considered
GST/HST Ruling
12 September 2017 GST/HST Ruling 142842 - Whether the Global Adjustment is considered as part of the consideration payable for the supply of electricity and therefore subject to the RITC requirement
As such, the GA is not considered to be a price adjustment for purposes of section 232. ... The GA meets all the requirements of the above test to be considered a tax. 2) Is the GA a Duty or Fee? ... Thus, the Ga would not be a fee, as electricity is considered to be tangible personal property. ...
22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] -- summary under Subsection 259(2)
22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]-- summary under Subsection 259(2) Summary Under Tax Topics- Excise Tax Act- Section 259- Subsection 259(2) CEWS and TWS did not count towards 40% government funding A non-profit organization (NPO) generally is entitled to GST/HST public service body rebates if the percentage of its “government funding” (defined in s. 2 the Public Service Body Rebate (GST/HST) Regulations) is at least 40%. ...
Folio Summary
S4-F14-C1 - Artists and Writers -- summary under Business Source/Reasonable Expectation of Profit
Some objective factors to be considered when determining if there is an intention to profit identified in Stewart were: the profitability of prior years, the taxpayer’s training, the taxpayer’s intended course of action, and the capability of the venture to show a profit. Factors considered in determining whether the artist’s activity is a business 1.24 Factors which should be considered by the artist or writer in determining whether the artist’s or writer’s activity is undertaken in a sufficiently commercial or business‑like manner include: the amount of time devoted to the artistic or literary endeavours; the extent to which an artist or writer has presented their works in public and private settings including, but not limited to, exhibiting, publishing, and reading as is appropriate to the nature of the work; the extent to which an artist is represented by an art dealer, agent, or mandatary and the extent to which a writer is represented by a publisher or literary agent; the amount of time devoted to, and type of activity normally pursued in, promoting and marketing the artist's or writer's own works; the amount of revenue received that is relevant to the artist's or writer's own works including, but not limited to, revenue from sales, commissions, royalties, fees, grants, and awards which may reasonably be included in business income; the historical record, spanning a significant number of years, of annual profits or losses relevant to the artist's or writer's exploitation of their own works; the type of expenses claimed and their relevance to the endeavour(s) (for example, in the case of a writer there would be a positive indication of business activity if a substantial portion of the expenses were incurred for research); the artist's or writer's qualifications as an artist or writer, respectively (for example, as evidenced by training, education, or by public and peer recognition received in the form of honours, awards, prizes, and/or critical appraisal); membership in any professional association of artists or writers whose membership or categories of membership are limited under standards established by that association; and the significance of the amount of gross revenue derived by an artist or writer from the exploitation of that individual's own works and the growth of such gross revenue over time. ... In order for the taxpayer to be considered to have undertaken the activity in pursuit of profit, i.e. to be considered to be carrying on business, the artistic or literary endeavours must be carried on in a sufficiently commercial or business-like manner. ...
Folio Summary
S1-F3-C4 - Moving Expenses -- summary under Eligible Relocation
Reduction of daily commute considered personal 4.31... Example 1 An individual lives in dwelling A in Halifax with his family for five years and then moves his family and all of his belongings to dwelling B in Brampton in order to be employed in downtown Toronto. ... Dwelling A is considered the old residence, and dwelling C the new residence. ...
Public Transaction Summary
Dixie/VisionSky -- summary under Trust Acquisitions of Corporations
The exchange of the VKY common shares for the VKY cash and the VKY Class B shares (presumably having a nominal value) is considered as qualifying as a reorganization of the capital of VKY under s. 86. ... Neither the VKY Class B shares nor the NewCo shares are considered by management to be taxable Canadian property. ... The Trust The existing structure is not considered to result in the Trust holding non-portfolio property. ...
Public Transaction Summary
InnVest REIT -- summary under Fund Debenture Offer
" Take-up "A Resident Holder who disposes of Series G Debentures pursuant to the Offer will be considered to have dispose of such Series G Debentures for proceeds of disposition equal to the Offer Price (other than the portion of the Offer Price received as interest, including any premium deemed to be interest as described below)." Part XIII tax "By virtue of the fact that the Series G Debentures are convertible into Units of the REIT, there is a risk that both (i) the amount of the Offer Price that exceeds the principal amount of the Series G Debentures (the "Excess"); and (ii) all interest paid or deemed to be paid to a Non-Resident Holder in connection with the Offer could be considered to be participating debt interest, in which case Canadian withholding tax would apply. ...
Public Transaction Summary
Holland Global/Maplewood REIT -- summary under CPC/Microcap Conversions
The REIT will not be considered to be a SIFT trust provided that (as stipulated in the investment guidelines) it does not own any non-portfolio property. ... Netherlands tax consequences B.V. and Maplewood Operating LP are considered domestic and foreign tax residents, respectively. ... B.V. will hold the legal ownership of the Initial Property, whereas beneficial ownership will be held by Maplewood Operating LP, which will be considered to have a Dutch branch business. ...
Public Transaction Summary
Anderson/Freehold -- summary under Taxable spin-offs
Anderson then will transfer most of its assets to New Anderson, other than shallow gas assets (which are considered to be non-core assets) in consideration for assumption of liabilities and the issuance of New Anderson common shares – which will then be distributed to New Anderson for cancellation as a stated capital distribution. ... Accounting As New Anderson will be considered to be under common control, IFRS 3 will not apply. ...
Public Transaction Summary
KWG Resources -- summary under Share Consolidation
"On the Capital Reorganization, a shareholder will be deemed to have disposed of the Common Shares for proceeds of disposition equal to their adjusted cost base to such shareholder and will be considered to have acquired the Subordinate Voting Shares for proceeds of disposition at a cost equal to the same amount. ... " Conversion "On the conversion of Subordinate Voting Shares held by a shareholder into Multiple Voting Shares pursuant to the terms of the Subordinate Voting Shares, no disposition will be considered to occur and therefore the shareholder will not realize a capital gain or incur a capital loss…. ...
Public Transaction Summary
Brilliant Resources -- summary under Ss. 84(4.1)(a) and (b) distributions of proceeds
S. 84(4.1) does not apply to the Return of Capital, provided that (i) the Return of Capital can reasonably be considered to have been derived from proceeds of disposition realized by the Corporation (or by a person in which the Corporation had a direct or indirect interest at the time the proceeds were realized, such as the Subsidiary) from a transaction that occurred outside the ordinary course of the business of the Corporation (or the Subsidiary) but within the period that commenced 24 months before the Return of Capital, and (ii) no other amount that may reasonably be considered to have derived from such proceeds was paid by the Corporation as a reduction of paid-up capital prior to the Return of Capital. ...