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While the residence status of an individual can only be determined on a case by case basis after taking into consideration all of the relevant facts, generally, unless an individual severs all significant residential ties with Canada upon leaving Canada, the individual will continue to be a factual resident of Canada and subject to Canadian tax on his or her worldwide income. ... The circumstances must be examined as a whole, but it is nevertheless obvious that considerations based on the personal acts of the individual must receive special attention. ...

Although consideration should be given to the availability and quantum of support provided, a person is generally considered to be dependent on an individual if the latter has actually supplied necessary maintenance out of their own resources. ... Consideration should be given to the relationship between the eligible person with a disability and the other individual throughout the particular period during which support was provided, to determine whether the relationship as a whole was one of dependency. 2.31.2 Where the eligible person with a disability was in receipt of social assistance or any other type of financial or non-financial support, the supporting individual must be able to show that the other assistance was insufficient to fully meet the basic needs of the eligible person with a disability and that the person had to rely on the additional support provided by the supporting individual. 2.31.3 In the context of ¶2.31.2, financial support involves providing money in order for the person to acquire the basic necessities of life such as food, shelter, and clothing. ...

Where foreign taxes have been paid to a jurisdiction that has a tax treaty with Canada, special attention must be paid to that treaty as it may affect how section 126 applies. 1.3 Before determining the amount of foreign tax credit available to a taxpayer, consideration must be given to the type of income earned. ... Another consideration that must be taken into account before calculating the amount of the foreign tax credit available is the nature of the foreign taxes paid. ... For purposes of deciding this question, consideration should be given to any relevant case law. ...

In making such a determination, the amount of severance that the employee would reasonably be entitled to will be taken into consideration. 2.18 Similarly, general damages relating to human rights violations can be considered unrelated to a loss of employment. ...

The term commercial obligation is defined in subsection 80(1). 1.39 Capital gains included in the foreign accrual property income of a foreign affiliate of a corporation cannot be added to the corporation’s CDA. 1.40 The calculation of the non-taxable portion of a capital gain for the purposes of Component 1 of the CDA at any time in the year takes into consideration any amount deducted as a reserve at the corporation’s year-end pursuant to subparagraph 40(1)(a)(iii) in respect of proceeds of disposition of a property that are payable to the corporation after that year-end. ... Generally, the reduction under clause (d)(v)(A) is the amount by which the fair market value of the consideration given in respect of the disposition of the policy exceeded the greater of the value of the interest in the policy (generally, the cash surrender value) and the adjusted cost basis of the policy to the policyholder immediately before the disposition. ...

For example, a lender may make a loan that is not prompted by the ordinary considerations that govern its money-lending business. ... In a given situation, one factor for consideration is the normal commercial practice that could be expected under similar circumstances. 1.68 At the time the loan is made, the arrangements for repayment must be such that it is possible to determine, with some certainty, the period within which the loan will be repaid. ...

Although the determination of the amount of the advantage in each year is a question of fact, the cost of equivalent term-life insurance coverage based on insurance underwriting considerations such as the individual’s age, gender, and health would be a relevant factor. ... It would also give rise to an advantage described in ¶ 3.16(b) as it is reasonable to consider that the dividend payments were made in substitution of the corporation paying bonuses or other remuneration to the employees in consideration for services rendered. ...

Such requests should be directed to: Collections and Verification Branch Validation, Policies, and Procedures Section Canada Revenue Agency 3rd Floor, 395 Terminal Avenue Ottawa ON K1A 0L5 Canada Eligibility of United States educational institutions 2.14 The eligibility under paragraph 118.5(1)(c) of a United States educational institution to which a student commutes from Canada (see ¶2.10(b)) is determined by the CRA on an individual basis by applying considerations similar to those used in determining the eligibility of Canadian educational institutions under subparagraph 118.5(1)(a)(i). ... As such, once the amount of eligible tuition, education, and textbook tax credits available for transfer is determined pursuant to section 118.81, the actual amount of the student’s unused tax credits that may be claimed by the student’s spouse or common-law partner is subject to an additional calculation which takes into consideration the possible transfer of unused child, age, pension, and disability tax credits of the student, as follows: A + B – C The variables in this formula are as follows: A is the total of the tuition, education, and textbook tax credits that the student transferred to a spouse or common-law partner for the year, pursuant to section 118.81. ...

Premiums paid to a private health services plan (PHSP) 1.133 Subject to the exception discussed at ¶1.135, paragraph 118.2(2)(q) provides that any premium, contribution or other consideration (including GST, PST, HST and premium taxes) that an individual has paid to a PHSP for that individual, the individual’s spouse or common-law partner, or a member of the household with whom the individual is connected by blood relationship, marriage, common-law partnership or adoption may be an eligible medical expense. See Interpretation Bulletin IT‑339R2 and the web page Private Health Services Plan. 1.134 Premiums, contributions or other consideration paid to provincial medical or hospitalization insurance plans are not eligible medical expenses. 1.135 To the extent premiums, contributions or other consideration paid to a PHSP are deducted under subsection 20.01(1) in computing an individual’s income for any tax year from a business carried on by the individual, the amounts are not deductible under paragraph 118.2(2)(q). ...

Private health services plan premiums, contributions, or other consideration paid for by the trust cannot be claimed by an employee under paragraph 118.2(2)(q) as eligible medical expenses. ...