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Technical Interpretation - External

19 October 1993 External T.I. 9316475 F - Indians

Before finalizing its guidelines, the Department is seeking input from representative Indian groups, to determine their views as to what other factors, if any, should be considered when connecting employment income to a location on or off a reserve. ...
Technical Interpretation - Internal

4 October 1993 Internal T.I. 9319827 F - Auto Lease Cancellation Payment

In order for an amount to be considered an "actual lease charge", it must be payable pursuant to the lease and relate to the use of the vehicle by the lessee. ...
Administrative Letter

28 October 1993 Administrative Letter 9326076 F - Past Service RPP Contribution - Foreign Salary

The following is a brief summary of the relevant facts: XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX Our Comments: It is our view that the provisions of subsection 8503(15) of the Regulations provide for and were intended to provide for circumstances such as those being considered in XXXXXXXXXX case. ...
Technical Interpretation - External

21 October 1993 External T.I. 9328525 F - Retiring Allowance Instalments Rolled to RRSP

Although we cannot comment on whether any of the payments you have described could be considered a "retiring allowance" within the meaning of subsection 248(1) of the Income Tax Act (the "Act"), we offer the following comments concerning the paragraph 60(j.1) deduction. ...
Miscellaneous severed letter

8 November 1993 Income Tax Severed Letter 9330395 - Retiring Allowance, Re-employment

Such a payment will not be considered a retiring allowance, however, where, between the date of the notice of retirement or of termination and the last day of employment, arrangements are made for the employee to be rehired. ...
Technical Interpretation - External

29 October 1993 External T.I. 9300065 F - Income Derived From Royalties (4093-U5-100-12)

In that case the court did not determine the meaning of the word "derived" in isolation, but rather it considered the scheme and intention behind the provisions in the Income Tax Act which contained incentives to economic activity. ...
Miscellaneous severed letter

22 October 1993 Income Tax Severed Letter 9306138 - Prepaid Funeral Sevices

Department officials in conjunction with The Funeral Service Association of Canada reviewed this matter and I can assure you that your suggestion was considered. ...
Technical Interpretation - Internal

19 November 1993 Internal T.I. 9316317 F - Private Health Services Plan

Special foods or beverages are considered to be "medicaments, or other preparations or substances" as that phrase is used in paragraph 118.2(2)(n) which requires that two other conditions be met in order for those costs to be eligible; (1) that they be prescribed by a medical practitioner and (2) that the item be purchased from a licensed pharmacist who has recorded the prescription in his prescription record. ...
Miscellaneous severed letter

25 November 1993 Income Tax Severed Letter 9318565 - Automobile Allowances

You have also mentioned that you travel approximately XXXXXXXXXX each month in carrying out your employment duties and have asked us to confirm that, if the municipality pays you a car allowance of $XXXXXXXXXX a month, this allowance would be considered a non-taxable benefit. ...
Technical Interpretation - External

24 November 1993 External T.I. 9331475 - Surplus Pot Shares — Disposition

For example, if as indicated in paragraph 2 of IT-448, the amendment to the share's terms involves a cancellation of the share, then by virtue of clause 54(c)(ii)(A) of the Act, the shareholder will be considered to have disposed of the share. ...

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