Search - considered

" The issue raised in this case does not appear to have been previously considered by either the Department or the courts. ...

Consequently, it is our view that this amount is employment income pursuant to subsection 5(1) and/or 6(3) of the Act and that the amount cannot be considered a retiring allowance. ...

XXXX You have requested our opinion as to whether the costs incurred by the participants in attending these seminars will be considered to be deductible from income for tax purposes if the participants do not remain in Florida after the cessation of the seminars. ...

Would you please prepare a remission report in accordance with the guidelines set out in TOM 2263.24 and provide us with any relevant information or correspondence which may assist us in our review, together with your recommendation as to whether remission should be favourably considered. ...

Furthermore, investment income and proceeds of disposition of such investments are not considered to be foreign property provided they are immediately converted to Canadian currency or promptly used to acquire property that is not foreign property. ...

(Pursuant to paragraph 1. of your memo, even though Part B of the form was never completed and the conditions therein not satisfied, the certificate could still legally be considered a valid certificate). ...

In other words, where property is transferred to a bare trust the settlor will be considered to be the owner of the property for income tax purposes. ...

It is our opinion that the amount of XXXX is not deductible by the estate since this amount is not considered, a speaking, as property income under section 9 of the Income Tax Act. ...

Day (613) 957-2136 JAN 22 1987 Dear Ms Martin: We are writing in response to your letter of December 18, 1986, wherein you requested our views regarding which taxation year retiring allowances will be considered to have been received for T4A reporting purposes. ...

In particular you queried whether a building which is owned by a PBC and situated on land leased by the PBC be considered real property owned by the PBC for purposes of subsection 18(3.4) of the Act. ...