Search - considered

Results 5841 - 5850 of 49131 for considered

Birchcliff Energy Ltd. v. Canada, 2019 FCA 151

In such a case, whether a transaction is abusive will only become apparent when it is considered in the context of the series of which it is a part and the overall result that is achieved (Lipson, at para. 34, per LeBel J.). ...

Fiera Foods Company v. The King, 2023 TCC 140

The reliability of the evidence is what is paramount.... [14] In this case, reliability is a particular concern because at the time of the hearing, the Relevant Period had commenced nearly 12 years prior and many of the subpoenaed witnesses worked at the Appellant’s premises for only a short period of time. [15] With respect to each fact witness, I have considered all relevant factors [5] and I have concluded that each fact witness is credible. [6] I will address issues of reliability in the context of the evidence. ... They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The word “includes” indicates that the List is intended to exemplify the types of forms that may exist but is not exhaustive of those forms. [304] In Caisse populaire Desjardins de l’Est de Drummond v Canada, 2009 SCC 29 (“ Caisse populaire ”), the Court considered the meaning of “security interest” in subsection 224(1.3) of the ITA. ...

Burns v. The Queen, 94 DTC 1370, [1994] 1 CTC 2364 (TCC)

Fisher stated at page 17 (D.T.C. 193): For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly and reasonably determines to be uncollectable at the end of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact be collected. ...

Policy Statement P-051R2 "Carrying on Business in Canada" 29 April 2005 -- summary under Subsection 240(1)

Ex. 1 A non-resident lessor (with a leasing business outside Canada) is considered to be carrying on business in Canada by virtue of a sale-leaseback transaction under which it purchases a conveyance from a resident registrant, with delivery under the sale agreement and under the lease-back to the resident (who will use the conveyance partly in Canada) occurring in Canada, notwithstanding no other significant connecting factors to Canada. ...

GST/HST memorandum 9.4 "Reimbursements" June 2012 -- summary under Subsection 175(1)

Instead, as the employer, partnership, charity or public institution would be considered to be the recipient of the supply, the usual rules for determining whether that person was eligible to claim ITCs or rebates would apply. ...

23 May 2013 IFA Round Table Q. 6(f) -- summary under Paragraph 212.3(10)(c)

(iii) A final bona fide repayment would not be considered part of a series for the purpose of s. 212.3(10)(c)(i), so that a particular amount owing by a subject corporation to a CRIC which arose in the ordinary course of its business of the CRIC would meet the exception if its final bona fide repayment was made within 180 days after the day on which it became owing. ...

IT-533 "Interest Deductibility and Related Issues" 31 October 2003 -- summary under Paragraph 20(1)(c)

In situations where some proportion of shares is being replaced with borrowed money, only the capital of those shares, computed on a pro-rata basis, would be considered to be replaced with the borrowed money. ...

2 December 2014 CTF Roundtable, Q. 1 -- summary under Derivative Forward Agreement

Where the terms of an exchangeable share permit the taxpayer to exchange its shares with the issuer for shares of another company, would ancillary rights enabling such taxpayer to put its shares to another person for the shares of the other company in the event the issuer is unable to effect the exchange be considered to be an agreement for purposes of the DFA definition? ...

TPM-02R Secondary Transfer Pricing Adjustments, Repatriation and Part XIII Tax Assessments 1 June 2021 -- summary under Subsection 247(12)

Where a lower amount of Part XIII tax would be due when compared to the amount previously remitted, a refund may be considered if requested within two years from the end of the calendar year in which the withholding tax was initially remitted, as per s. 227(6) (para. 17). ...

IC00-1R3 "Voluntary Disclosures Program" March 21, 2013 -- summary under Subsection 220(3.1)

If the CRA accepts a disclosure as having met the conditions set out in this policy, it will be considered a valid disclosure and the taxpayer will not be charged penalties or prosecuted with respect to the disclosure. ...

You are here