Search - considered

After noting that the corporation would be required to allocate the costs of the equipment between SR&ED and commercial activities, the Agency went on to indicate that labour, subcontracting, and materials expenses of a current nature relating to SR&ED activities that were "expenditures on or in respect of scientific research and exterior experimental development" as defined in s. 37(8)(a) to develop equipment that would be used 90% or more in the research laboratory and for equipment considered to be multi-purpose equipment, would qualify as current expenses for the purposes of s. 37 and for the calculation of the investment tax credit. ...

Before referring to the Oerlikon decision as to the meaning of “advance,” the Agency stated: [P]repaid expenses that are presented in the financial statements of one corporation and that are granted to another corporation (except a financial institution) are considered in computing the investment allowance under paragraph 181.2(4)(b) of the Act as a “loan or advance”. ...

. … [T]he factors to be considered include whether the firefighter was subject to former subparagraph 6(1)(b)(viii), the nature of the duties performed, whether the firefighter can accept or refuse to report for duty based on availability, the total annual remuneration paid to the firefighter, and the maximum exemption amount provided for in proposed subsection 81(4). ...

CCRA found that such fees did not qualify as child care expenses, indicating that: Meal costs are not normally considered child care expenses since they are excluded from that definition in s. 63(3)(d); and Fees paid for supervised activities, such as extracurricular activities, are not part of child care expenses since they are not generally incurred for the purpose of providing child care. ...

3 March 2000 Internal T.I. 2000-0002337 F- COOPERATIVES-- summary under Credit Union Summary Under Tax Topics- Income Tax Act- Section 137- Subsection 137(6)- Credit Union Quebec cooperative did not qualify as a credit union in light of not being incorporated under the Credit Unions Act and not having statutory authorization to conduct business as a credit union A cooperative incorporated under the Quebec Cooperatives Act did not qualify as a credit union as defined in s. 248(1) (so that it did not qualify for the exclusion from a specified investment business in s. 125(7)), given that a the cooperative could not be considered to be organized as a credit union where, as here, it was incorporated under the Cooperatives Act and not under the Credit Unions Act. ...

In finding that the cooperative did not qualify as a credit union as defined in s. 248(1), so that it did not qualify for the exclusion from a specified investment business, the Agency stated that the cooperative could not be considered to be organized as a credit union since it was incorporated under the Cooperatives Act and not under the Credit Unions Act. ...

The fact that they were connected internally and shared a common basement did not mean that they could be considered a single domestic establishment. ...

However, where the service went beyond simple advice and included both preventative or curative treatment and advice, the service would be considered a taxable benefit unless it was part of the service included in a private health services plan. ...

., then the child is considered to be "living" with that second caregiver during the periods when the second caregiver has custody. ...

C-26) may be considered an educational institution offering post-secondary courses for the purposes of section 118.5. ...