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Technical Interpretation - Internal
24 August 1990 Internal T.I. 901299 F - Insured RRSPs
Segregated fund investment would be included in insured plans if they are part of plan which otherwise would be considered to be an insured plan. ...
Technical Interpretation - Internal
28 May 1991 Internal T.I. 9106407 F - Tax Treatment of Wood-chip Bins
It is also stated that an asset would be considered to have been acquired primarily for a specified purpose where it is to be used more than 50% of the time for that purpose. 24(1) CCA Classification Class 3 provided for property not included in any other class that is, inter alia, a building or other structure, or part thereof acquired by the taxpayer before 1988. 24(1) Class 29 generally includes, inter alia, property acquired by a taxpayer after May 8, 1972 and before 1988 to be used directly or indirectly by him in Canada primarily in the manufacturing or processing of goods for sale and that is property that would be included in Class 8. 24(1) Cost of Manufacturing and Processing Capital The cost of M&P capital must be determined in order to calculate a taxpayer's M&P credit under section 125.1 of the Act. ...
Technical Interpretation - External
31 October 1989 External T.I. 58365 F - Principal Residence — Meaning of "Ordinarily Inhabited"
Short (613) 957-2134 October 31, 1989 Dear Sirs: Re: Meaning of "ordinarily inhabited" as used in Paragraph 54(g) of the Income Tax Act (the "Act") This is in reply to your letter dated July 12, 1989 (File No. 40053/340) wherein you have asked whether a taxpayer could be considered to have "ordinarily inhabited" a particular housing unit, within the meaning of that expression found in paragraph 54(g) of the Act, in any of the years from 1972 to the present in the particular circumstances set forth in your correspondence. ...
Technical Interpretation - Internal
14 August 1990 Internal T.I. 901587 F - Charitable Gifts
We are of the view that the words, "an amount payable on a periodic basis" in the definition of "in subsection 248(1) of the Income Tax Act, requires that there be more than one annuity payment in a contract before it can be considered to be an "annuity" contract. ...
Technical Interpretation - Internal
29 August 1989 Internal T.I. 58559 F - Deductibility of Prior Year Non-capital Losses
As discussed in our telephone conversation of August 28, 1989, advance income tax ruling requests are only considered in respect of identified taxpayers and in accordance with the guidelines contained in Information Circular 70-6R issued by Revenue Canada, Taxation (the "Department"). ...
Ruling
17 June 1991 Ruling 910951 F - Definition of Family Farm Corporation
The person would ordinarily be expected to contribute time, labour and attention to the business to a sufficient extent that such contributions would be determined in the successful operation of the business This is in contrast to a passive shareholder or investor who would not be considered to be "actively engaged" As for the phrase "actively involved on a regular and continuous basis", the regularity and frequency of involvement in the management and/or day to day activities of the farming business will depend on the nature of the farming operation and is determined on the facts of the situation. ...
Ruling
6 February 1991 Ruling 902711 F - Definition of "Expenditure Base" - Logging Tax Deduction
Finally, in your view the Limited Partner's expenditure base in respect of the Partnership on December 31, 1990 is $100 on the basis that the $99 payment made on February 1, 1990 is, for the purpose of subparagraph 127(8.2)(a)(ii) of the Act, an amount "described in subparagraph 53(1)(e)(iv) contributed by the taxpayer after the time he last became a limited partner of the partnership and before the end of the year that may reasonably be considered to have increased the taxpayer's at-risk amount in respect of the partnership at the end of the taxation year in which the contribution was made. ...
Ruling
14 July 1989 Ruling 58083 F - Principal Residence Exemption
Please refer to Interpretation Bulletin IT-221R2 "Determination of an Individual's Residence Status" (copy enclosed) for further information on factors to be considered in determining an individual's ordinary place of residence. ...
Technical Interpretation - External
22 August 1990 External T.I. 901710 F - Gifts by Staff to a University
In determining whether the 24(1) should issue a receipt in respect of a contribution by an individual staff member, the following guidelines should be considered:- Amounts should be paid to the 24(1) and must be unconditional.- Any designated purpose should be part of the general activities of the 24(1) for which donations would normally be accepted.- Generally, individuals who have made such contributions and who wish to propose that 24(1) funds be expended on particular activities should submit applications for funds or equipment to a committee responsible for administering such funds or equipment for the particular activities.- Such an application should adequately document the proposed use of the funds or equipment.- Funds or equipment should only be allocated to the individual or his department after applying the standard evaluation criteria for such allocation.- Any equipment purchased or expenditures made with contributed funds must be of such a nature that it would be reasonable for the 24(1) to acquire such equipment or expend such funds and the usual controls with respect to the use of 24(1) equipment or expenditure of 24(1) funds should be in force.- There can be no direct connection between the amount of the individual's contribution and disbursement from the fund or allocations of equipment to that person, nor should there be any option to purchase equipment acquired with the funds at the end of a certain time period. ...
Ministerial Correspondence
3 September 1991 Ministerial Correspondence 912094 F - Winding-up of Subsidiary
The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990. ...