Search - considered

We have also considered the application of paragraph 118.2(2)(o) of the Act, which deals with amounts paid for laboratory, radiological or other diagnostic procedures or services prescribed for a patient by a medical practitioner or dentist. ...

Roy, CGA Ottawa ON K1A 0R5 March 15, 2004 Dear Mrs Chainé: Re: Severance Pay This is in reply to your email of February 20, 2004 wherein you requested an interpretation on whether payments pursuant to the amendment proposed to an agreement would be considered a retiring allowance that is eligible to be transferred under paragraph 60(j.1) of the Income Tax Act (the "Act") to a registered retirement savings plan. ...

In general terms, amounts or benefits received by an employee arising out of or in consequence of the cessation of employment are considered income from that employment. ...

Also, the leave would commence after the individual has ceased employment, thus it cannot be considered to be a leave of absence. ...

We may "look-through" an arrangement where the trust may reasonably be considered to act as an agent for the beneficiaries. ...

As discussed in paragraph 15 of Interpretation Bulletin IT-120R6, Principal Residence ("IT-120R6") factors that are considered by the CRA in determining this question of fact include:? ...

Because of these presumptions, the shares of a foreign affiliate or of a controlled foreign affiliate included in the assets of the partnership would not be considered a foreign affiliate or a controlled foreign affiliate of the partner and that partner would not have to report it on form 1134-A or 1134-B. ...

Position: No Reasons: The payment represents a voluntary personal gift to the individual as a result of his status as a union member and would therefore is not considered a payment to "compensate for the loss of employment" as contemplated by subparagraph 56(1)(a)(ii) of the Act. ...

A taxable benefit will be considered conferred on the employee to the extent the employee's personal use of the cellular phone has contributed to additional charges over and above the price of the basic plan. ...

The guide includes a detailed discussion of the numerous factors considered in determining whether a particular individual is an employee or self employed. ...