Search - considered

CRA Response The question of the creation date of a testamentary trust has been considered in past STEP Roundtables. ... X would be considered to have been made at a time other than a non-resident time of Mr. ... Consequently, the contribution would not be considered to have been made at a non-resident time of Mr. ...

The CRA interprets Schedule V as a list of exempt supplies that must be considered and applied independently. ... What aspects of the original policy statement were considered problematic so as to require removal of P-249? ... Is only the $1M considered taxable as the “amount paid” under s. 182 and GST/HST would be deemed included in this amount – so that the interest and indemnity amounts would be considered non-taxable? ...

In our view, the wording of paragraph (a) does not support the interpretation that the test is that the beneficiary’s interest must be acquired as a result of the particular transfer being considered. ... The proceeds received in respect of the disposition of a property of a trust would be considered substituted property. ... Fron: In each case, the deemed dividend that arises on ACo’s acquisition of its own shares would be considered to be paid by ACo in its new taxation year. ...

On the short sale, it is the borrowed securities that the short seller is considered to have disposed of. ... Both dispositions must therefore be considered. Generally, as stated in paragraph 18 of Interpretation Bulletin IT-479R, gains or losses on short sales of securities are considered to be on income account. ... Generally, a right to receive an amount may be considered to be a right or thing of an individual within the meaning of subsection 70(2). ...

., in a M&A type of transaction can be considered as payment for the settlement of such indemnities or proceeds of disposition of shares being disposed of in such transaction. ... Therefore, the amount considered to be paid for the repurchased shares under subsection 84(3) should be equal to the amount of settlement for the indemnity claim. ... In that particular case, the corporation was considered to be a resident of Singapore for the purposes of the Canada-Singapore Tax Treaty, provided that its central management and control was at all relevant times exercised in that jurisdiction. ...

(d) Incapacitated taxpayer The situation described above would not be considered as an exclusion to EFILE. ... Would a beneficiary of a trust that has an interest in the corporation be considered to hold an interest? Would a trustee of a trust that has an interest in the corporation be considered to hold an interest? ...

The Queen (TCC) 2015 TCC 42], which considered the income or capital characterization of the taxpayer’s gains on foreign currency derivatives. ... Can the CRA confirm that it still follows this “two-step” approach, and can you update us on any new entities or arrangements that are being considered? ... (The German version of the Treaty was not considered to be an official version.) ...

S. 94(3) trust holding "CCPC" A trust which meets the conditions of section 94 is considered resident for certain purposes of the Act. ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Recent TIs Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

B considered to have received a designated benefit by virtue of her being alive at the time of the formation of the estate on the death of Mr A? ... CRA considered that the addition to the capital dividend account (CDA) of each of Corporation B and Corporation C was $300,000 (=$500,000-$200,000), not $400,000. ... If the receivable is not a capital property, any gain attributable to a fluctuation in the value of the currency would be considered to be income from a business or property, and any loss sustained would be considered as a loss from a business or property. ...

Notes From Presentation In brief, a guarantee made for no fee is considered to be an investment in the subject corporation (Forco) by the CRIC in these circumstances. ... Similarly, there is considered to be a conferral of a benefit when the CRIC guarantees debt of a subject corporation for no fee. ... The amount deductible is the amount that the taxpayer can demonstrate can reasonably be considered to have been deductible by the taxpayer pursuant to paragraph 113(1)(a) in respect of the exempt surplus of a FA of the taxpayer at the lending time, assuming that the amount lent was instead paid by the creditor affiliate or partnership as a dividend. ...