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Accordingly, such expenses would normally be considered part of the cost of the acquired property and not deductible under paragraph 20(1)(e). ...

Where the individual does not provide POA services in the course of carrying on a business, the compensation is considered to be income from an office and is included in the individual’s income in the year of receipt under paragraph 6(1)(c) of the Act. ...

The definition of “permissible distributions” in paragraph 8502(d) of the Income Tax Regulations (“ITR”) seems to provide that the portion of the IPP minimum amount that is not described as a “payment of benefits in accordance with the plan as registered” is considered to be a “permissible distribution”. ...

In such case, it is our view that the entire amount of the rental payments can be considered to be “rent from real or immovable properties” for purposes of that definition in subsection 122.1(1) of the Act. ...

30 July 2019 Ministerial Correspondence 2019-0814471M4- Deductible Union Dues Unedited CRA Tags 8(1)(i) Principal Issues: Whether certain amounts that were paid by an individual would be considered union dues that would be deductible under paragraph 8(1)(i) of the Act. ...

We have carefully considered the information that you have provided, but our position remains unchanged. ...

Reasons: A non-resident individual that does not have any Canadian source income would not be considered a “taxpayer” as it is defined in the Act and therefore would not be eligible for the Disability Tax Credit. ...

According to the Scheme website, the payment is not considered “income or profits derived from an office or employment or from carrying on a business or letting of premises” and therefore is not subject to tax in Hong Kong. ...

As all of these factors would have to be considered in reference to any particular insurance policy, we are unable to provide a more specific response to your query. ...

You have requested confirmation that wage loss replacement plan will be considered an employee-pay-all plan for the period during which the following three criteria are present: 1.      ...