Search - considered
Results 4941 - 4950 of 49345 for considered
Article Summary
Gwendolyn Watson, "The Foreign Affiliate Surplus Reclassification Rule", Canadian Tax Journal (Canadian Tax Foundation) (2019) 67:4, 1233-66 -- summary under Subsection 5907(2.02)
These cases considered the issue in the context of property that ceased to exist under the doctrine of merger in connection with the transfer. ...
Article Summary
Nelson Whitmore, Owen Strychun, "Canadian Inbound Investment After the MLI", Canadian Tax Journal, (2019) 67:3, 831-80 -- summary under Article 7(1)
According to the commentary, even though state R's extensive treaty network was considered by the fund in determining where RCO should be formed, it would not be reasonable to deny treaty benefits to RCO in this circumstance since the company was established to deliver on the commercial mandate of the fund to buy and sell real estate investments. ...
Article Summary
Lee A. Sheppard, "The Brave New World of the Dependent Agent PE", Tax Notes International, Vol. 71, No. 1, 1 July 2013, p. 10 -- summary under Article 5
Roche considered whether the subsidiary did the parent's business in Spain. ...
Technical Interpretation - Internal
14 March 2014 Internal T.I. 2013-0499141I7 - IRC 338(h)(10), "earnings" and safe income
No, any capital gain realized on a subsequent disposition of the shares of the purchaser could not reasonably be considered to be attributable to the Intangible Property Safe Income for purposes of subsection 55(2) of the Act. ... Second Issue V.2 Reasonably be considered to be attributable to anything other than income earned or realized 33. ... The issue, therefore, becomes whether, in interpreting the phrase "reasonably be considered to be attributable" in subsection 55(2), the gains that accrued on FA's US Holdco shares in the Post-acquisition period and, therefore, the gains that accrued on PrivateCo's XXXXXXXXXX Canco common shares immediately before their redemption on XXXXXXXXXX, could reasonably be considered to be attributable to the Intangible Property Safe Income or to something else. ...
FCA
Canada v. Construction Bérou Inc., 99 D.T.C 5869 (FCA)
Such conditions only add corroborative support where a transaction can be considered to be a sale under the circumstances stated in 3 above. 6. ... The meaning of the word "acquired" as used in section 20(5) was fully considered by my brother Cattanach J. in The Minister of National Revenue v. ... His interest in the property had gone far beyond that arising from a merecontract [sic] of purchase and sale of the type considered in Wardean Drilling Ltd., supra. ...
Old website (cra-arc.gc.ca)
Third-Party Payments Policy
Legislative reference Income Tax Act Paragraph 37(8)(c) SR&ED expenditures related to a business, restriction 4.3 When SR&ED is considered a business The prosecution of SR&ED, in and by itself, is only considered a business of the claimant to which the SR&ED relates, if the claimant derives all or substantially all of its revenue from the prosecution of SR&ED. ... Income from the performance of SR&ED carried out on behalf of another taxpayer is generally considered to be revenue from the prosecution of SR&ED. ... This investment income will not be considered as part of the third-party payment. ...
Current CRA website
Third-Party Payments Policy - 2014
Legislative reference Income Tax Act Paragraph 37(8)(c) SR&ED expenditures related to a business, restriction 4.3 When SR&ED is considered a business The prosecution of SR&ED, in and by itself, is only considered a business of the claimant to which the SR&ED relates, if the claimant derives all or substantially all of its revenue from the prosecution of SR&ED. ... Income from the performance of SR&ED carried out on behalf of another taxpayer is generally considered to be revenue from the prosecution of SR&ED. ... This investment income will not be considered as part of the third-party payment. ...
Current CRA website
Third-Party Payments Policy
Income from the performance of SR&ED carried out on behalf of another taxpayer is generally considered to be revenue from the prosecution of SR&ED. ... If the results of the SR&ED are in the public domain before the sponsor receives them, then that would not be considered to be a preferential right. ... This investment income will not be considered as part of the third-party payment. ...
Current CRA website
Social events and hospitality functions
If the gift card meets all these conditions, it is considered non-cash for the purpose of the CRA's administrative policy. If the card does not meet these conditions, it is considered a near-cash benefit and is taxable. ... The employer provided gift cards (which meet the conditions for the card to be considered non-cash) of $50 to 75 employees and not the spouses or common-law partners to cover the cost for meal, beverage and delivery service. ...
Archived CRA website
ARCHIVED - Woodlots
If the woodlot is not a commercial woodlot, it is considered a non-commercial, or hobby, woodlot. ... STEP I: IS THE WOODLOT CONSIDERED A COMMERCIAL WOODLOT OR A NON-COMMERCIAL WOODLOT? ... Income received from an adventure or concern in the nature of trade is considered to be business income under the Act. ...