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In the case of taxpayers who are considered non-filers, there is no statute-barred limit to observe. ... An emission allowance is a right and, as such, is considered intangible personal property. ... Where the option or contract can only be settled in money it may be considered a financial instrument. ...

Before it can be concluded that an amount is payable within the meaning of subsection 104(13), subsection 104(24) must be considered. ... In particular, is the gain considered to be from a source in Australia for purposes of computing the foreign tax credit? ... Prior to the time when the estate administration is complete, the executors are generally considered to hold legal and beneficial ownership of the estate property and the estate is still considered to be in existence. ...

Although it is too early to confirm anything yet, rest assured, all possible solutions are being considered. ... Re (a), Deltona considered the formation by amalgamation of a corporation to be its “incorporation.” ... The non-resident lessor is considered to be in the business of supplying tangible personal property by way of lease. ...

It is considered to be one of the hallmarks indicative of a genuine intergenerational business transfer. ... The Bare Trust would also be considered to be a trust for the purposes of paragraph (k) of the definition of disposition. ... So in the situation described in Part A of the question, although a disposition of the bond may well be considered to have occurred on the maturity of the bond, this is not considered to be a disposition by the Bare Trust. ...

A corporation that is considered a loan corporation for purposes of the Income Tax Act would also be considered a “loan corporation” for purposes of the draft SLFI Regulations. ... Will the “New Lessor’s” supplies be considered to have been made outside of Canada? ... CRA Comments A partnership is considered to be a person for GST/HST purposes. ...

Where an individual is considered to reside in Canada and another country, treaties must be taken into account, and the tie-breaker rules must be considered, which are cascading tests that must be applied in sequence. ... Stays would have to be considered. Again, if we get to the habitual abode, the other elements of the individual’s residence and of the centre of vital interests would not have been determinative, so stays would have to be considered, and the nature of the activities of the individual in a given country would be considered as well, to determine whether the individual usually lives in that state or not compared to the other. ... The court considered a matter that is essential to the CRA’s ongoing efforts to protect Canada’s tax-base and the integrity of tax treaties. ...

All factors that may affect the value of any unit in the building must also be considered. ... Canada, considered how to determine whether or not there is income from a source for the purpose of section 9. ... Similarly, the more an individual's involvement is integral to the success of the business, the more it would be considered important. ...

CRA has considered cash pooling in the context of s. 15(2) and similar principles will apply here. ... How much of the loan funded by FA may reasonably be considered to be related to the loan made by the Intermediate to Canco must be evaluated. ... Can the CRA provide a brief overview of the types of issues considered by the Directorate in recent ruling requests related to paragraph 4? ...

Would a mandatory quarantine period (imposed by the Canadian government or a foreign government) be considered a Travel Restriction? ... When is an individual’s presence in Canada considered to be “solely as a result” of Travel Restrictions? ... Q.5 — Directors Forced to Stay in Canada In the guide, CRA has considered the issue of corporate residency as it relates to directors who may be forced to travel to or remain in Canada. ...

X would only be considered to own the Shares so received from the date of the distribution. ... X's will, that acquisition is considered to be an acquisition made as a consequence of Mr. ... That acquisition will also be considered an acquisition of property made as a consequence of Mr. ...