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Folio Summary

S3-F6-C1 - Interest Deductibility -- summary under Exempt Receipts/Business

For other taxpayers it will generally be considered a non-taxable capital receipt. ...
Folio Summary

S5-F1-C1 - Determining an Individual’s Residence Status -- summary under Subsection 120(1)

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Subsection 120(1) Summary Under Tax Topics- Income Tax Act- Section 120- Subsection 120(1) "An individual who is resident in more than one province on December 31 of a particular tax year will be considered to be resident only in the province in which the individual has the most significant residential ties, for purposes of computing his or her provincial tax payable. ...
Folio Summary

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime -- summary under Section 3

If the class "B" shareholders considered that the lawyer's work had also benefited them, any payment made by the class "B" shareholders to the lawyer would be taxable income.... ... The Queen, [1997] 3 CTC 2363, 97 DTC 1416, a pool player who in cold sobriety would challenge inebriated pool players to a game of pool was held to be taxable on his winnings. 1.15 …[T] he following criteria should be considered in making the determination [of business]: the degree of organization that is present in the pursuit of this activity by the taxpayer, the existence of special knowledge or inside information that enables the taxpayer to reduce the element of chance, the taxpayer's intention to gamble for pleasure as compared with any intention to gamble for profit as a means of gaining a livelihood, and the extent of the taxpayer's gambling activities, including the number and frequency of bets. ... This will be the case unless, due to the circumstances applying to the lottery scheme, the prize can be considered to be income from employment, business or property, or a prize for achievement referred to in paragraph 56(1)(n). ...
Folio Summary

S1-F1-C1 - Medical Expense Tax Credit -- summary under Paragraph 118.2(2)(j)

Fees paid to a medical practitioner for eye exams and treatments, such as laser eye surgery, are generally considered eligible medical expenses under paragraph 118.2(2)(a).... ...
Folio Summary

S2-F1-C1 - Health and Welfare Trusts -- summary under Nature of Income

[P]enalties charged by a health and welfare trust for the late remittance of employer contributions would be considered incidental income. ...
Folio Summary

S5-F4-C1 - Income Tax Reporting Currency -- summary under Subsection 261(21)

The rule applies to deny a loss to the taxpayer where the loss can reasonably be considered to be attributable to a fluctuation in the value of the taxpayer’s tax reporting currency relative to the related corporation’s tax reporting currency during the period in which the loss accrues. ...
Folio Summary

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph (a)

S3-F10-C3- Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (a) 3.6 “Where a benefit or debt is connected in any way with the existence of a plan, it is considered to be conditional on the existence of the plan.” ...
Folio Summary

S3-F6-C1 - Interest Deductibility -- summary under Subsection 16(1)

"Contracts having terms greater than one year would be considered to include both simple interest (deductible on a paid or payable basis), as well as compound interest (deductible only on a paid basis). ...
Folio Summary

S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 56(1)(o)

S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 56(1)(o) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(o) Travel expenses are typically allowable research expenses, but if the researcher establishes a temporary base away from home then the taxpayer may be considered to be residing there- in which case many expenses that would otherwise be travel expenses, such as food and rent, would become living expenses. ...
Folio Summary

S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 56(1)(o)

S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 56(1)(o) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(o) Grants given to a person outside of a corporation's or university's own organization are considered to be research grants under s. 56(1)(o) regardless of whether the research belongs to the grantor or recipient (para. 3.61). ...

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