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Folio Summary
S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance -- summary under Paragraph 8(1)(n)
S1-F2-C3- Scholarships, Research Grants and Other Education Assistance-- summary under Paragraph 8(1)(n) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) After noting that education-related expenses paid by an employer are considered employment income (at paras. 3.11-3.12), CRA stated: 3.13 Where a student is required to repay an employer for education expenses the employer previously incurred on their behalf, the student will be entitled to deduct the repayment under paragraph 8(1)(n) where the repayment is made by or on behalf of the student in the year pursuant to an arrangement requiring the reimbursement of any amounts received for a period throughout which the student did not perform the duties of the office or employment. ...
Folio Summary
S1-F1-C1 - Medical Expense Tax Credit -- summary under Paragraph 118.2(2)(k)
S1-F1-C1- Medical Expense Tax Credit-- summary under Paragraph 118.2(2)(k) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(k) Although insulin substitutes are not covered under paragraph 118.2(2)(k), they are generally considered drugs, medicaments and other preparations or substances, the cost of which is an eligible medical expense under paragraph 118.2(2)(n) provided the requirements under that provision are otherwise met. ...
Folio Summary
S5-F2-C1 - Foreign Tax Credit -- summary under Non-Business-Income Tax
Examples of taxes which do not qualify as business income taxes, but which may be considered non-business income taxes (para. 1.21., 1.27) are: U.S. taxes on U.S. business income of an S-Corp which is levied on the U.S. ...
Folio Summary
S4-F8-C1 - Business Investment Losses -- summary under Paragraph 50(1)(a)
A debt is considered bad for the purpose of section 50 when the whole amount is uncollectible.... ...
Folio Summary
S3-F3-C1 - Replacement Property -- summary under Paragraph 44(5)(b)
In this respect, two businesses will be considered to be similar if they both fall within the same one of the following categories: merchandising- retailing and wholesaling; farming; fishing; forestry and forest products; extractive industries, including refining; financial services; communications; transportation; construction, including subcontracting; and manufacturing and processing. 1.42 With regard to the categories referred to in ¶1.41, where a business falls into more than one, a similar business will be one that falls into any one of these categories in which the business operates. ...
Folio Summary
S6-F2-C1 - Disposition of an Income Interest in a Trust -- summary under Subsection 108(7)
However, if a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...
Folio Summary
S3-F6-C1 - Interest Deductibility -- summary under Paragraph 20(1)(c)
Prevailing yields should be considered. 1.22-1.24. Loan v. unpaid amount. ... [W]here accrued interest is added to the outstanding principal amount of an existing loan resulting in a new obligation or novation, an interest payment will not be considered to have been made. ... Where [loan issuance] premium arises because the debt was deliberately priced to give rise to a premium, the interest expense otherwise deductible will not be considered reasonable. ...
Folio Summary
S1-F2-C2 - Tuition Tax Credit -- summary under Subparagraph 118.5(1)(a)(i)
An organization, professional or otherwise, that provides evaluation, examination, or other such services, but does not provide educational courses, is not considered to be an educational institution for purposes of paragraph 118.5(1)(a); c) An educational institution is not ineligible under subparagraph 118.5(1)(a)(i) solely by reason of the fact that it provides other courses in addition to post‑secondary school level courses; or d) An institution in Canada that has been designated as a specified educational institution under the Canada Student Loans Act or that has been recognized for the purposes of the Canada Student Financial Assistance Act or An Act respecting financial assistance for education expenses of the Province of Quebec is presumed to satisfy the eligibility requirements. ...
Folio Summary
S4-F7-C1 - Amalgamations of Canadian Corporations -- summary under Subsection 87(7)
.]… 1.59 Where control of a corporation is acquired and that corporation makes a designation under paragraph 111(4)(e) to realize an accrued foreign exchange gain on a foreign currency denominated debt that arises because of the application of subsection 111(12), the new corporation formed on a subsequent qualifying amalgamation of that corporation would, under paragraph 87(7)(d) and for the purposes of subsections 40(10) and (11), be considered to be the corporation that realized the gain in respect of the foreign currency denominated debt under paragraph 111(4)(e) and subsection 111(12). ...
Folio Summary
S5-F4-C1 - Income Tax Reporting Currency -- summary under Subsection 261(6)
The taxpayer's income or loss from the partnership for the fiscal period ending October 31, 2015 would be determined in Canadian currency then, pursuant to paragraph 261(5)(c), would be converted to the electing taxpayer's elected functional currency based on the days the relevant amounts are considered to arise. ...