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This generally will not be a practical concern if a temporary indulgence respecting payment on the due date is not considered to be an "extension" of the debts' maturity date. ...

The Explanatory Notes further state that officers will be considered to work principally in Canada, or in the residence country of a connected affiliate: if they spend the majority of their working time in Canada or the connected affiliate's country, and also carry out a majority of their important functions, and make most of their important decisions, with respect to the CRIC in that country. ...

However, that residual dividend of $500 would be considered to be paid to Parent and, depending on the terms of the applicable treaty (if any), that dividend might not be eligible for a Treaty-reduced rate of 5%. ...

By virtue of s. 212.3(15), where a chain of non-resident corporations control the Canadian-resident corporation, only the 1st tier non-resident corporation is considered to be the parent for these purposes. ...

Under most corporate statutes, an amalgamated corporation is considered to be a continuation of the amalgamating corporations (Guaranty Properties), so that the amalgamated corporation may execute an election on behalf of one of its predecessors. ...

Given this practice, it might be considered that its primary purpose is to invest its fund primarily in partnership interests, which are financial instruments. ... It likely is not intended that they are to be considered to have an “interest” in the borrower partnership. ... As is discussed in relation to Example 1 above, there is perhaps a risk that the holding LP would be considered to satisfy the primary-purpose test, so that it would be an ILP, with a commensurate risk that general partner distributions made by it would be subject to GST/HST (as well as mildly onerous SLFI filing and remittance obligations being generated). ...

Second, the incurring of losses in the year of the designation would have the effect of reducing or eliminating the amount of the additional income which otherwise could be considered to have been allocated to the unitholders, so that the deduction for the following year would be reduced or eliminated accordingly. ...

" Numerical example of application of SAM formula Assumptions In 2015 MFT incurs third-party expenses of $1 million, which are subject to federal GST of $50,000 and Ontario HST of $80,000, as all such supplies are considered to be made in Ontario. ...

In order for $30 of this PUC to be restored under draft s. 212.3(9) on the distribution of FA2, it must be considered that this distribution occurred on the same class of shares which sustained the s. 212.3(7) grind. ...

" As under canon law, Roman Catholic pastoral agents (unlike ordained ministers) were not considered to have a permanent status, they did not qualify as regular ministers. ...