Search - considered

Position: No Reasons: Each drawdown is considered a separate obligation and each must be measured from date of draw to expiry date of facility XXXXXXXXXX 981683 J. ... It is the view of the Department that each such drawdown is, for the purpose of determining whether the borrower may be obliged to repay more than 25% of the principal amount of that obligation within five years from its date of issue, considered to a separate obligation of the borrower. ...

Reasons: According to Revenue Collections, XXXXXXXXXX trainees would be considered employees of XXXXXXXXXX. ... In this regard, we understand that the Revenue Collections Directorate has opined that XXXXXXXXXX training program is considered pensionable and insurable employment. ...

For the purposes of calculating a taxpayer’s capital gain, or loss, from the disposition of shares of a merging foreign corporation in exchange for shares of the merged corporation, the taxpayer generally will be considered to have received proceeds of disposition equal to the fair market value of the merged corporation shares received on the exchange. ... Since tax policy issues and amendments to the Act are the responsibility of the Department of Finance, any changes would have to be considered by that Department. ...

Paragraph 16.1(1)(b) of the Act deems that, for the purpose of computing the income of the lessee, the lessee is considered to have acquired the subject property from the lessor. ... For that same reason, such alterations or additions would not be considered to be leasehold improvements of the lessee for the purpose of a claim for capital cost allowance. ...

Position TAKEN: 60(j.1) can only be applied in the year that an amount is considered to be received and taxed under 56. ... If an amount is taxable when it is due, an employee will be considered to have received it at that time and subparagraph 56(1)(a)(ii) of the Income Tax Act as consolidated to June 10, 1993, (the "Act") will apply. ...

Principal Issues: Whether front end load charge on the purchase of an annuity contract that is a RRSP can be considered an administration fee, deductible as a carrying charge for the annuitant? ... Roy Attention: XXXXXXXXXX July 4, 1994 Dear Sir\Madam: Subject: Deductibility of RRSP Administration Fee This is in reply to your letter of May 16, 1994 in which you requested our opinion on whether a front end load on an RRSP bought by a client can be considered an administration fee, deductible as a carrying charge. ...

It was also indicated that we did not agree with the suggested treatment whereby a portion of an NPI so "disqualified" would be considered to be a Canadian resource property. Discussion In our view, the agreement or other documentation creating an NPI would have to be considered in order to properly determine the treatment to be accorded that NPI for the purposes of the Act. ...

If an election under subsection 98(3) of the Income Tax Act (the "Act") is not made, (a)at what point is each partner considered to have disposed of its partnership interest? (b)will each partner obtain the increase in the adjusted cost base of its partnership interest pursuant to subparagraph 53(1)(e)(viii) and subsection 66.4(6) of the Act before the partner is considered to have disposed of his partnership interest? ...

However, the actual receipt of the payment in 1996 would not be considered as income. ... For the landowner, the portion of the payment given to the lessee is not considered a transition and it does not affect the landowner,s income. ...

You inquire whether the bequest made by the deceased taxpayer in the will could be considered to be a bequest to the foundation established for the particular university. As the foundations established pursuant to the University Foundations Act, 1992 are separate entities from the universities for which they are established, where a will provides for a donation to a university, in our view, the will would not be considered to be providing for a donation to its established foundation. ...