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11 August 1997 External T.I. 9626335- WHETHER MULTIPLE PROPERTIES CONSIDERED "A PROPERTY? ...

Would a tax avoidance arrangement generally be considered a misrepresentation? ...

Cash which is temporarily surplus to the needs of the business and which is invested in short-term income producing investments may be considered to be used in the business. Cash balances which accumulate and are then depleted in accordance with the annual seasonal fluctuations of an ongoing business will generally be considered to be used in the business, but a permanent balance in excess of the company's reasonable working capital needs will generally not be considered to be so used. ... [C]ash and near cash assets held to offset the non-current portion of long term liabilities will not generally be considered to be used in the business. ...

9 August 2019 External T.I. 2019-0813021E5- TOSI and excluded shares-- summary under Paragraph 96(1)(f) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(f) partner carries on business of partnership CRA considered that: Where the jurisdictional law regarding partnerships provides that a partnership is an agreement among the partners to carry on business in common, each partner will be considered to be carrying on the business of the partnership. Accordingly, where an inactive spouse held 10% (by votes and value) of a Partnerco of a partnership carrying on an active non-services partnership, the Partnerco would be considered to carry on directly the “related business” (i.e., the business of the partnership), so that the test to this effect in the “related share” definition in s. 120.4(1) would be considered to be satisfied. ...

Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize the business. 3. Cash which is temporarily surplus to the needs of the business and is invested in short-term income producing investments could be considered to be used in the business. 4. Cash balances which accumulate and are then depleted in accordance with the annual seasonal fluctuations of an ongoing business will generally be considered to be used in the business but a permanent balance in excess of the company's reasonable working capital needs will generally not be considered to be so used. 5. ...

Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize the business. 3. Cash which is temporarily surplus to the needs of the business and is invested in short-term income producing investments could be considered to be used in the business. 4. Cash balances which accumulate and are then depleted in accordance with the annual seasonal fluctuations of an ongoing business will generally be considered to be used in the business but a permanent balance in excess of the company's reasonable working capital needs will generally not be considered to be so used. 5. ...

LLC would be considered a corporation, that the ownership interest of a member would be considered shares, and that distributions would be considered to be dividends. ...

LLC would be considered a corporation, that the ownership interest of a member would be considered shares, and that distributions would be considered to be dividends. ...

Should Individual A be considered financially dependent on his father at the time of his father's death so that amounts could be transferred from the father's RRSP as a refund of premiums? CRA stated: Some of the factors which may be considered in making [the] financial dependency determination include the income of the child from all sources, the cost of living and the ability of the child to provide for self-support, and any support received by the child from other persons. … [I]f a child is living with another individual who is providing support for the child at the time of the annuitant's death, the child would not be considered to be financially dependent upon the deceased for support at that time. ... Consequently … Individual A would not be considered to be financially dependent on the deceased at the time of death for the purpose of a deduction under paragraph 60(l)….. ...

(b)(ii) of “foreign resource property” in s. 248(1), that “for such mineral right to be considered specified foreign property, the right would have to be tangible property, which is understood to include real property such as land and rights issuing out of, annexed to and exercisable within or about land,” and that the mineral right would be considered a tangible property coming within s. (b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. Therefore…a mineral right situated outside Canada would be considered a specified foreign property pursuant to paragraph (a)…. ...