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S. 94(3) trust holding "CCPC" A trust which meets the conditions of section 94 is considered resident for certain purposes of the Act. ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Recent TIs Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

CRA Comments As indicated above, A Co.’s disclosure is not considered to be a valid voluntary disclosure. ... As per the definitions contained in the Wash Transaction policy, this situation is not considered a wash transaction. ... Legally, it seems that the initial assessment is still valid, even though administratively it's considered to be cancelled. ...

Notes From Presentation In brief, a guarantee made for no fee is considered to be an investment in the subject corporation (Forco) by the CRIC in these circumstances. ... Similarly, there is considered to be a conferral of a benefit when the CRIC guarantees debt of a subject corporation for no fee. ... The amount deductible is the amount that the taxpayer can demonstrate can reasonably be considered to have been deductible by the taxpayer pursuant to paragraph 113(1)(a) in respect of the exempt surplus of a FA of the taxpayer at the lending time, assuming that the amount lent was instead paid by the creditor affiliate or partnership as a dividend. ...

Note that all requirements must be met under the ITA to be considered a designated member for the purpose of the assignment and similarly for the allocation of the business limit from the partnership and those requirements have not been considered in the response. ... The issue will be considered further and discussed with our Publications staff in HQ. ... A transcript faxed subsequent to the original processing review response often is not considered, either. ...

CRA has considered whether its Large Business compliance approach is in line with a cooperative compliance regime and whether we should introduce a formal pre-filing review program. ... Are any initiatives being considered by the CRA to improve the corporate tax assessment process in the ITSO? ... When a subsidiary corporation is wound up into a parent corporation, it ceases to exist as a legal entity and cannot be considered part of the parent corporation. ...

The creation of a separate telephone enquiries line for representatives is not being considered at this time. ... Adding additional filtering options may be considered for future enhancements. ... If the return was fled by October 1, it was considered to have been fled on time. ...

Question Would the interest be considered by the CRA to be with respect to the lending of money”, as described is subparagraph 149(1)(c)(ii) of the ETA? ... In general, a building that is of a permanent nature and affixed to land is considered to be “real property” as defined in subsection 123(1) of the ETA. ... Generally, the sale price for the property is considered to include the tax. ...

In a scenario where the corporation has income from the provision of services and from income from non-services, the two should generally be computed separately, and the non-service income considered in determining if the requirement of the definition is met. ... Subpart F income is not deemed to be income under Canadian domestic law, and thus would not be considered to be U.S. ... Subsection 75(2) of the Act applies so that the income of the alter ego trust is considered to be the income of the Settlor, who created the trust and who is, under the trust, a lifetime beneficiary. ...

Respecting the tests in s. 20(1)(c)(ii), it might be considered that the note was consideration for property acquired. ... In any other assessment, GAAR likely would be applied as the double-utilization of the SIOH would be considered to be abusive. ...

c) If this constitutes construction of a residential complex, would 5, or only the 1 additional unit, be considered to be constructed? ... Since NewCo is not considered to have constructed or substantially renovated the residential complex, it is not considered a builder for the purpose of paragraphs (a) nor (b) of the definition of “builder” in subsection 123(1). ... In this case, the coupon is not considered to be for a fixed dollar amount. ...