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In other words, in order for two individuals cohabiting in a conjugal relationship to be considered common-law partners in the first year of cohabitation, both individuals must be considered parents of a child. An individual can be considered the parent of a child for income tax purposes when they are either the biological or adoptive parent of a child. ... In most of these cases we would not expect that both criteria required for the cohabiting individual to be considered to be a "parent" of the child- i.e. ...

and (ii) Would time spent educating teachers and daycare providers be considered time spent administering therapy? ... Generally, teachers or daycare providers would not be considered to be primary caregivers. ... What would be considered essential to one person’s impairment may not be considered essential to another. ...

-resident company will be considered to own more than 10% of the voting shares of the corporation paying the dividend. ... -resident company will be considered to own 99.98% of the dividend payer's shares for the purposes of Article X(2)(a). 2009-031870 XXXXXXXXXX J. ... Therefore, such portion of the dividends paid by Canco will be considered to be derived by USco for the purposes of the Convention. ...

CRA Response Article IV(6) of the Treaty provides that an amount of income, profit or gain shall be considered to be derived by a person who is a resident of the U.S. ... Furthermore, pursuant to the Technical Explanation to the 2007 Protocol to the Treaty, where Article IV(6) applies to deem a U.S. resident to be considered to derive a Canadian-source dividend, such dividend is considered as being paid to that U.S. resident. As such, dividends paid by the ULC in the example provided above would be considered as being paid to USCo1 and USCo2. ...

Principal Issues: Is cash considered to be an asset used principally in an active business? ... Nevertheless, we offer our general views as to when cash or near cash property held by a corporation will be considered to be used in the course of an 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. ...

Railroad Retirement Act for Tier 1 and Tier 2 benefits considered social security taxes? ... One portion that is equivalent to the normal U.S. social security coverage and another portion that is not considered to be a U.S. social security benefit but is considered to be a benefit from a pension plan. The Tier 2 RRAA benefits are also considered to be benefits from a pension plan. ...

Where a debt bears only simple interest, any accrued and unpaid simple interest itself will not be considered to be an outstanding debt to a specified non-resident. Even where the simple interest bears compound interest, that simple interest will not be considered to be an outstanding debt to a specified non-resident until the compound interest is paid and is therefore deductible in accordance with paragraph 20(1)(d) of the Income Tax Act (the “Act”). ... (b) Where compound interest does accrue on unpaid simple interest and subparagraph 78(1)(b)(ii) deems the amount of that simple interest to be a loan, is that deemed loan considered to be an outstanding debt to a specified non-resident only when the compound interest has been paid? ...

None of the mileage described in the first example is considered incident to the discharge of the duties of employment. 2. ... Similarly, the travel from home to the memorial service and then to the church is considered employment-related but the travel from the church to home is considered personal. 4-6. None of the mileage described in examples 4, 5, and 6 is considered incident to the discharge of the duties of employment. 7. ...

Income earned on the disposition of commodities will not be considered to be derived from the disposition of marketable securities for purposes of the provisions noted in C. above but will be considered as being from an active business. ... A deposit left with a securities broker may be considered as being a cash deposit if it is left in that form for only a short period (one or two days). A margin deposit would otherwise be considered as a debt security which would have to comply with the relevant provisions governing the forms of investment allowable to a fund. ...

Would an amount included in income pursuant to subsection 94.1(1) of the Act be considered "aggregate investment income" as defined in subsection 129(4) of the Act? ... An amount included in income pursuant to subsection 94.1(1) would be considered to be from a source that is a property. ... An amount included in income pursuant to subsection 17(1) would be considered to be from a source that is a property. ...