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Whether the re-negotiated note would be considered to be accepted as "conditional payment" rather than as "absolute payment" is such a matter. ... The extension of the note could occur before the original due date and before the end of the vendor's taxation year for which the reserve is being considered. ... " Thus, it would appear, unless there is evidence to the contrary, that the re-negotiated note in your fact situation may be considered to be accepted as conditional payment and not as absolute payment. ...

The utility poles would in our view be considered separate assets or  properties which together with the conductors and lines comprise the electrical line system.  ... It would be considered an acquisition of a new asset with a useful life of 25-30 years. In our view the comments in paragraph 4 of IT-128R do not support your position that the pole replacement costs could be considered current expenditures.  ...

You have also asked whether there would be considered to be a change in use or conversion of capital property to inventory during the process of obtaining approval for the severance of lands. ... Corporations are considered to be associated if they meet any of the criteria set out in section 256 of the Act as amended by Bill C-139. Based on the facts as set out in your letter it would appear that none of the corporations established would be considered associated, as that term is defined in the Act. ...

Is a USLLC considered to be resident for treaty purposes to receive treaty benefits? ... Where the situs of mind, management and control is considered to be located elsewhere, USLLC may be considered resident in a different country. ... Where a distribution is considered a dividend and the recipient is considered a qualifying person pursuant to Article XXIX-A of the Treaty, Article X, if applicable, should limit the US tax withheld on the distribution to 15%. ...

3) Where a computer is purchased before the beginning of a sabbatical leave can the purchase of the computer be considered an allowable research expense? ... More than 30 days in one place will likely be considered sojourning. Reasons: 5(1), 56(1)(o) and IT-75R4 2005-011892 XXXXXXXXXX Luisa A. ...

It is our view, however, that where an asset, such as cash temporarily surplus to the needs of a business, is invested in short-term income producing investments, those investments may be considered to be used in the business. ... Rather such funds would be considered as permanently set aside for investment or non-qualified uses (i.e., uses other than for active business). ... In the Department's view, cash 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. ...

Principal Issues: Whether insurance proceeds received as a result of the destruction by fire of a business asset are considered an active business asset. Position TAKEN: Such insurance proceeds will generally be considered to be active business assets. ... In the Department's view, cash 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. ...

The rare circumstance where individuals insured under the policy actually share in the dividend or refund is now covered, and explained in the Technical Notes. 2.For an amount to be considered paid under the policy it must first become payable under its terms, then when the obligation is discharged in one form or another the amount would be considered paid. 961230 XXXXXXXXXX J.A. ... As a starting point in determining whether an amount is considered paid under the policy, it should first be determined whether the amount was payable under the terms of the policy. ... In our view, the amounts will be considered paid to the policyholder and to the extent that the account is accessed by employees, it will be considered distributed to individuals insured under the policy. ...

Prior to the wedding and following a divorce the parties to the union are considered to be "single", while during the period of the union the parties are considered to be married to each other. ... Q. 1If a common-law relationship is severed, are the individuals involved considered to be "single" or "separated"? ... Where the particular time being considered is within the 90 day period they would continue to be considered married, but separated, at the particular time unless the separation extends past the 90 day period. ...

Principal Issues: Is prefabrication of log homes (but not erection of log homes) considered construction and thus excluded from the M&P credit? Position: probably not considered construction Reasons: The Company is apparently not involved in the construction of the log homes only the supply of building materials- since the company is not involved in the construction of log homes the activity (preparing of log home components) would not be considered construction. ... Based on the limited information you provided, it would appear that the Company's activities of processing lumber for direct sale and the preparing of log home components could be considered M&P activities. ...