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Technical Interpretation - External

3 December 1997 External T.I. 9720065 - CARRYING ON BUSINESS IN CANADA - BANK ACCOUNT

Having said this, the mere fact that a non-resident corporation maintains a bank account in Canada for the purpose of paying its suppliers, in and of itself, will not cause the corporation to be considered as carrying business in this country for purposes of the Act. ...
Technical Interpretation - External

3 December 1997 External T.I. 9729205 - OVERSEAS EMPLOYMENT TAX CREDIT

Reasons: Whether can reasonably be considered an employee is a question of fact. 972920 XXXXXXXXXX David R. ...
Ministerial Letter

29 January 1998 Ministerial Letter 9728278 - STRIKE PAY, DED'N OF UNION DUES

Levies made during a year on some or all members of a trade union to provide funds for the prosecution of a legal strike of the union are considered to be annual dues provided that such levies are capable of recurring and have not been designated by the union as special assessments. ...
Ministerial Letter

3 February 1998 Ministerial Letter 9728788 - MEDICAL TRAVEL WITHIN THE CITY

Since tax policy issues and amendments to the Act are the responsibility of the Department of Finance, any changes to the rules regarding the eligibility of travel costs as medical expenses would have to be considered by that department. ...
Technical Interpretation - External

23 February 1998 External T.I. 9726465 - PRINCIPAL RESIDENCE

In addition, paragraph 22 of IT-120R4 indicates that a legally imposed minimum lot size exceeding 1/2 hectare at the time of acquisition, which is zoned as being residential, is generally considered to be the minimum amount of land necessary for the use and enjoyment of the housing unit as a principal residence throughout the period that the property is continuously owned by the individual after that acquisition date. ...
Technical Interpretation - Internal

11 March 1998 Internal T.I. 9718547 - INTEREST ON CAPITAL ASSETS ASSIGNED TO BANKRUPTCY TRUSTEE

If the trustee is acting as an agent for the taxpayer in the matter of the proposal, the income earned on the assets held by the trustee will be considered income of the taxpayer. ...
Technical Interpretation - External

30 March 1998 External T.I. 9730805 - ENTITLED TO RECEIVE

However, the phrase was considered in the Central Supply Company (95 DTC 434) case where the court noted, that section 4 of the Petroleum Incentives Act indicated in part that: "the applicant is... entitled on the requisition of the Minister to an incentive in the amount determined in accordance with... ...
Ministerial Letter

10 March 1998 Ministerial Letter 9733818 - T3 SLIPS - FILING DEADLINE

Considering that a trustee currently has less time to file the trust's income tax return (three months) than corporations (six months) and individuals (four months), changing the T3 filing requirements to further reduce the filing deadline was not considered appropriate at this time. ...
Ministerial Letter

26 January 1998 Ministerial Letter 9800108 - INDIAN EXEMPT EMPLOYMENT INCOME

In addition, the Guidelines are not intended to apply when it can reasonably be considered that one of the main purposes for the existence of an employment relationship is to establish a connecting factor between the income in question and a reserve. ...
Ministerial Letter

13 February 1998 Ministerial Letter 9733348 - HEMOPHILIACS WITH HEPATITIS C DAMAGES

Reasons: It is a question of fact whether the payments, if any, are to be considered compensation for general or special damages for personal injury or death. ...

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