Search - considered

Position: A dividend which has been declared, but not paid, is not considered to have been paid or credited and therefore no withholding tax is exigible under subsection 212(2). ...

We confirm that the above transfer can be made without Canadian withholding tax being levied at source because of Article XVII of the Canada-Netherlands Income Tax Convention providing, of course, that the recipient of the funds is considered to be a resident of the Netherlands. ...

MacDougall, M.P. for Timiskaming, concerning a request for remission of income tax with respect to the numerous employees affected by 24(1) Since the granting of the 24(1) remission order, all requests of this nature have been considered by officials of your Department. ...

We have completed our technical review of the September 19, 1985 submission by the Insurance Bureau of Canada and have informed officials of the Department of Finance where policy issues are being considered. ...

Consequently, the widow described in your letter would not be considered to be related to her deceased husband's brothers for purposes of paragraph 251(1)(a). ...

As discussed during our telephone conversation of July 14, 1984 XXXX Senecal), it is our opinion that the portion of a payment of a superannuation or pension benefit not subject to tax under Part XIII of the Act pursuant to subparagraphs (v) and (vi) of paragraph 212(1)(h) of the Act would nevertheless be considered as a "payment described in paragraph 212(1)(h) " for the purpose of paragraph 48(1)(b) of the Act. ...

In your letter you questioned whether Hong Kong would be considered as part of the United Kingdom for purposes of the Canada-United Kingdom Income Tax Convention. ...

"Profits" referred to in Article III(1) of the Canada- Denmark Income Tax Agreement are not considered to include capital gains realized in the disposition of taxable Canadian property. ...

Ward would appear to be incorrect as XXXX sojourned in Canada for more than 182 days in 1973 and would therefore be considered to be a resident of Canada in that year. ...

Nancy Kelly REW 4109-U3 Tax Convention (1980) Canada- United States Article XIX In answer to you enquiry of February 20, 1986 and further to our recent telephone conversation, we confirm that the duties of the employees of the United States Postal Service are considered to be functions of a governmental nature for the purposes of Article XIX of the Canada- United States Income Tax Convention. ...