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It might have been considered that the share value corresponding to the tax withholding amount was to be treated as cash or quasi-cash resulting effectively from the disposition of rights under s. 7(1)(b) (or (b.1)), so that the corporate tax deduction on such portion would not be prohibited by s. 7(3)(b). ... S 7(3)(b) precludes deduction for in-bound recharge (p. 19) The payment of recharges (respecting when a subsidiary reimburses its the parent for the cost of stock options or share awards granted by the parent to the subsidiary's employees) is not considered to result in the conferral of a benefit on the parent. ...

The answer in many statutory contexts is that the set of transactions must bear a family resemblance to those that Parliament could reasonably be considered to have had in mind in invoking the series concept as a means of anti-avoidance. ... The court would then attempt to ascertain whether the transactions carried out by the taxpayer bore a sufficient family resemblance to that stylized set of transactions or events to be considered a series for the purposes of that particular statutory invocation of the term. ... That being said, in our view, the option grant should not form part of the series for a more fundamental reason—namely, that the option grant does not bear any family resemblance to the types of transactions that Parliament can reasonably be considered to have had in mind when it enacted subparagraph 88(1)(c)(vi).... ...

The loss business was the sale of an electronic shelf labelling system used to register and display prices on grocery shelves, but did not extend to the use of that technology in other industries in the absence of any evidence that other applications had been considered by the Lossco prior to the acquisition. ... Integration of loss business into that of acquiror (p.9:16) Where the loss business is integrated into the business of the acquiror, it is unclear whether the similar business test even has to be considered. ... The court held that the fact that it was not necessary to create a separate division to operate the loss business activities was considered evidence of the similarity between the loss business and the integrated business. ...

The IA definition provides that the word "corporation" "does not include a partnership that is considered to be separate legal entity under provincial law."… [T]he better view is that the IA definition confirms that a partnership that is considered to be a separate legal entity should nevertheless be considered to be a partnership. … [T]here is a strong argument that the IA definition applies for greater certainty to ensure that LLLPs and LLPs are not treated as corporations. Further, the phrase "a partnership which is considered to be a separate legal entity under provincial law" does not necessarily limit the application of the IA definition to partnerships governed by provincial law. ...

", International Tax Planning, 2011, p. 1136-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Contrary to a CRA suggestion "there does not appear to be any Canadian authority requiring that a foreign entity 'issue capital stock' in order to be considered a 'corporation'.... ...

Broadhurst, "Financing by Non-Residents", 1992 Corporate Management Tax Conference Report, pp. 9:10-9:18-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Discussion of whether a non-resident purchaser of accounts receivable would be considered to be carrying on business in Canada. ...

Joint Committee, "Avoidance of Tax Debts", 5 April 2022 Joint Committee Submission-- summary under Paragraph 160(1)(c) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1)- Paragraph 160(1)(c) Exclusion of s. 251(5)(b) rights There should not be considered to be non-arm's length status by virtue only of rights described in s. 251(5)(b). ...

Questions of natural justice are considered to be questions of law and reviewed on the same standard:…[fn 24: Waycobah First Nation... 2010 FC 1188..., aff'd 2011 FCA 191.... ... See also Cogesco... 2013 FC 1238 at paras 18-20... and 3500722 Canada... 2008 FC 554....] the Federal Court allowed the application for judicial review on the basis that the court was unable to determine on the record whether the CRA considered certain facts that the court considered relevant: … In the early years of the administration of subsection 220(3.1), it was more common for the Federal Court to find a lack of independence within the CRA during the process of subsequent reviews. ...

.-- summary under Subsection 106(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 106- Subsection 106(2) Requirements for valid disclaimer of income interest (pp. 340 A taxpayer who executes a valid disclaimer of an income interest in a trust is generally considered not to have acquired the income interest….In order-to constitute a valid disclaimer for these purposes, the CRA's position is that the refusal must occur within a reasonable time after the recipient becomes aware of the gift or interest and before the recipient accepts any funds or benefits in respect of the gift or interest. However, if die taxpayer accepts any funds from the trust in respect of die income interest or executes a disclaimer in respect of the income interest in favour of another- person, the taxpayer is considered to have acquired the income interest and therefore cannot execute a valid disclaimer. ... Distinction between disposition and termination (p. 349) The CRA has considered a situation in which an estate of which the deceased's wife was the income beneficiary for life and her sons-were the capital beneficiaries was wound up in accordance with a court order, her income interest was terminated prematurely, and the capital was distributed to the sons. ...

Casuccio, "The Requirement to Register, Charge and Remit GST/HST on the Provision of Executor Services", Sales and Use Tax, Vol XI, No. 4, 2011, p. 598-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business Suggests (partly based on IT-377R, para. 5) that fees received from an estate by an individual who does not normally act as an executor may not be considered to be from a business. ...