Search - considered

7 August 1991 Income Tax Severed Letter- Receipt of Rent-reduced Accommodation in Exchange for an Interest Free Loan Considered a Barter Transaction Unedited CRA Tags none Subject: XXX This is in reply to your Round Trip Memorandum of July 12, 1991 which enclosed letter from XXX Our stated opinion with regard to similar programs is that rent reductions received as a result of interest-free loans by tenants are generally subject to taxation. Receipt of free or rent-reduced rental accommodation in exchange for an interest free loan is considered to be a barter transaction. ...

13 September 1990 Administrative Letter 901946 F- Indian Band Council Considered Canadian Municipality Unedited CRA Tags 110(1)(a)(iv), 118.1(1) total charitable gifts   19(1) 901946   Bill Guglich   (613) 957-2102   EACC9656 September 13, 1990 19(1) In a letter dated July 24, 1990, Ms. Anita Boscariol of Indian and Northern Affairs Canada requested that we provide you information as to whether your band council could be considered a Canadian municipality for purposes of issuing income tax receipts for charitable gifts. ...

24 August 1989 Income Tax Severed Letter AC58287- Winding-up- When a Dividend is Deemed Paid and a Shareholder Considered to Have Disposed of Shares 5-8287 19(1) D. ... Specifically, you requested an opinion as to when subsection 84(2) of the Act deems a dividend to have been paid and when, during the course of a wind-up, a shareholder is considered to have disposed of shares for the purposes of subsection 164(6) of the Act. ...

13 September 1990 Income Tax Severed Letter ACC9656- Indian Band Council Considered Canadian Municipality W.P. ... Anita Boscariol of Indian and Northern Affairs Canada requested that we provide you information as to whether your band council could be considered a Canadian municipality for purposes of issuing income tax receipts for charitable gifts. ...

7 July 1991 Income Tax Severed Letter- Whether a supplementary pension fund could be created and not be considered to be a retirement compensation arrangement Unedited CRA Tags 245(2) Dear Sirs: This is in reply to your letter of May 6, 1991, addressed to our Registration Directorate and referred to us for reply. You have asked if a supplementary pension fund could be created and not be considered to be a Retirement Compensation Arrangement or "RCA", if the employer's contributions thereto are included in the participating employees' income at the time of the contribution and any amounts of related investment income are included in income as they are earned. ...

7 July 1991 Income Tax Severed Letter- Whether an individual is considered to have received a benefit under subsection 15(1), 56(2) or 246(1) in a particular situation Unedited CRA Tags 15(1), 56(2), 89(1)(i), 246(1) Dear Sirs: Re: Subsections 15(1), 56(2) and 246(1) of the Income Tax Act (Canada) (the "Act") In your letter of September 20, 1990, you requested our views on the application of subsections 15(1), 56(2) and 246(1) of the Act. ... You have asked if the individual would be considered to have received a benefit under subsection 15(1), 56(2) or 246(1) in the above situation. ...

22 December 1989 Income Tax Severed Letter AC59176- Annuities Considered Qualified RRSP Investments December 22, 1989 Dear Sirs: This is in reply to your letter dated December 4, 1989 in which you asked whether a life annuity, a fixed term annuity or a term certain annuity are qualified investments for a trust governed by a registered retirement income fund (RRIF). ...

7 November 1991 Income Tax Severed Letter- Whether a mineral resource that is sold to another taxpayer is still considered a mineral resource Unedited CRA Tags 248(1) QUESTION 7. ...

7 June 1991 Income Tax Severed Letter- Islands that are considered to be a part of the country of Saint Vincent Unedited CRA Tags Reg. 5907(11) Dear Sirs: Re: Saint Vincent This is in reply to your letter dated April 23, 1991. ...

8 March 1990 External T.I. 74595 F- Patent Costs & Legal Fees Considered Capital or Income Expenditures Unedited CRA Tags 18(1)(b) VANCOUVER DISTRICT OFFICE HEAD OFFICE   Specialty Rulings Directorate J. ... With respect to the four questions posed at the close of your submission, our responses are as follows: a)     Because of the capital nature of the expenses, no amounts are deductible in computing the taxpayers income from any source. b)     The patent costs plus the legal costs incurred are capital expenditures that would be included in class 14 in schedule II once the patents themselves have been reacquired by the taxpayer. c)     In view of the above comments, it is our view that these costs cannot be considered "capital nothings". d)     Because these patents do no relate to the taxpayer's consulting business, no costs may be deducted from, nor CCA claimed with respect to, that business. ...