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In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. ... Income Tax Convention These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...

In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001 issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...

As a general rule, travel between one's residence and work location is considered to be personal travel. ... With respect to municipal officers specifically, as indicated in TOM 36(18)2(1), travel to and from school board, council meetings, etc., is considered to be personal travel. ... If, based on the circumstances, the allowance is not considered taxable by virtue of subparagraph 6(1)(b)(vii.1), it would also not be considered for purposes of calculating the exempt portion provided for by subsection 81(3). ...

Can land and timber be considered "qualified farm property" under subsection 110.6(1) of the Act? ... Can the land and timber be considered a capital asset in a "forest planting" situation? ... The sale of timber is considered income from the business of farming. ...

For United States tax purposes, CanLP will be considered to have disposed of the shares of Canco. ... USCo is considered to earn interest from the loan and USCo and USSub are considered to have incurred a proportionate share of the interest expense payable by ULC on the loan from USCo. ... Had ULC not been considered a disregarded entity, USCo would be considered to have made an interest-bearing loan to ULC. ...

Assuming that Country X is Canada and the merger takes place as described in paragraph 2 above, (i)     Shareholder B will be considered to have alienated his shares of BCo at their tax cost  and to have acquired the shares of ACo at that cost, (ii)     alternatively, Shareholder B and ACo may Jointly elect at a higher amount (but not exceeding the fair market value of the shares of BCo) and Shareholder B will be considered to have alienated his shares of BCo at such elected amount and to have acquired the shares of ACo at that amount, (iii)     on the liquidation of BCo, BCo will be considered to have alienated all of its property at its fair market value and ACo will be considered to have acquired such property at that fair market value. 8.      ... The tax consequences under the Act to ACo and BCo of such a merger are not clear and ACo and BCo may be considered to have alienated any property that becomes a property of ABCo as a result of the merger at the fair market value of such property and  ABCo may be considered to be a new corporation that acquired such property at a tax cost equal to the fair market value thereof.  ... Assuming that Country y is Canada and that the results of the merger are as described in paragraph 5-above, (i)     Shareholder B will be considered to have alienated his shares of BCo for an amount equal- to the fair market value of the shares of ABCo received by Shareholder B by virtue of the merger, (ii)     BCo will be considered CO have alienated all of its property at its fair market value and ABCo will be considered to have acquired such property at that fair market value, and (iii)     any income or gain realized by BCo on such alienation of property will be subject to tax-in Canada. 10.      ...

Assuming that Country X is Canada and the merger takes place as described in paragraph 2 above, (i) Shareholder B will be considered to have alienated his shares of BCo at their tax cost and to have acquired the shares of ACo at that cost, (ii) alternatively, Shareholder B and ACo may Jointly elect at a higher amount (but not exceeding the fair market value of the shares of BCo) and Shareholder B will be considered to have alienated his shares of BCo at such elected amount and to have acquired the shares of ACo at that amount, (iii) on the liquidation of BCo, BCo will be considered to have alienated all of its property at its fair market value and ACo will be considered to have acquired such property at that fair market value. ... The tax consequences under the Act to ACo and BCo of such a merger are not clear and ACo and BCo may be considered to have alienated any property that becomes a property of ABCo as a result of the merger at the fair market value of such property and-Co may be considered to be a new corporation that acquired such property at a tax cost equal to the fair market value thereof. ... Assuming that Country y is Canada and that the results of the merger are as described in paragraph 5-above, (i) Shareholder B will be considered to have alienated his shares of BCo for an amount equal- to the fair market value of the shares of ABCo received by Shareholder B by virtue of the merger, (ii) BCo will be considered CO have alienated all of its property at its fair market value and ABCo will be considered to have acquired such property at that fair market value, and (iii) any income or gain realized by BCo on such alienation of property will be subject to tax-in Canada. 10. ...

Whether more than one meal allowance may be provided during a period of overtime without being considered a taxable benefit. ... Less than three times a week will generally be considered infrequent or occasional. ... Therefore, the first meal allowance received by an employee would be considered a taxable benefit since it was received after one hour of overtime. ...

The situation you describe involves the accumulation of funds for a new business and whether those funds would be considered to be used in an active business. ... Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize 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. ...

Principal Issues: 1) is the purchase of a unit of a partnership involved in an active business considered investment of funds for 132(6)(b)(i)? ... Issue #5 Is the writing of covered call options by a Fund considered to be investing of its funds for the purpose of subparagraph 132(6)(b)(i) of the Act? ... In general, such transactions are considered ancillary to investing or part of a wide range of investing activities. ...