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In making a determination under section 68, the matter is to be considered from the viewpoint of both the vendor and the purchaser. ... In these latter circumstances, the demolition of the building is considered a disposition and may result in a capital loss in the purchaser's hands. ... Where the land area disposed of exceeds that necessary for the use of the building, paragraph 13(21.1)(a) is considered to apply only in respect of the portion that is necessary for the use of the building. ...

A builder who is considered to have collected the HST on a self-supply is required to report that amount on its GST/HST return for the reporting period during which the self-supply occurred. ... Rebate when taxable sale of new housing is made A GST/HST rebate is generally available to a non-registrant builder at the time the builder makes a taxable sale of new housing to another person or is considered under the self-supply rules to have made a taxable sale of the new housing. ... New residential rental property rebates The new residential rental property rebate in respect of the federal part of the HST that a non-registrant builder is considered to have collected on a self-supply of new housing continues to be available to eligible builder-landlords and is not affected by the HST rate increase in Prince Edward Island. ...

The taxable amounts shown in box 16 do not include: the amounts directly transferred on breakdown of a marriage or common-law partnership as reported in box 35; the amounts considered to have been received by the deceased RRIF annuitant just before death; the amounts that the deceased RRIF annuitant's child or grandchild has received or is considered to have received as a designated benefit from a RRIF; and the income earned on RRIF property after the year that follows the year of the RRIF annuitant's death. ... Box 18 – Amounts deemed received by the annuitant – Deceased The deceased annuitant of a RRIF is considered to have received, just before death, an amount equal to the fair market value (FMV) of the RRIF property at the time of death. ... This includes the following situations: at the time of the payment, the spouses or common-law partners were separated and living apart because of a breakdown of their relationship; the contributor spouse or common-law partner died during the year the payer made or is considered to have made the payment; or at the time of the payment, either the RRIF annuitant or the contributor spouse or common-law partner was a non-resident. ...

. ¶3.8 (formerly included in ¶6 of IT-75R4) has been expanded to include certain skills (such as certified first aid and truck driver training courses) in the list of examples of the fields of study to which a scholarship or bursary may be considered to apply. ¶3.9 (formerly included in ¶6 of IT-75R4) has been expanded to include additional examples of the types of educational expenses that may fall within the scope of subparagraph 56(1)(n)(i) if paid or reimbursed through a scholarship or bursary program, in line with various CRA interpretations. ¶3.10 has been added to note that the taxability of a scholarship or award in an employment situation is dependent upon the particular facts and circumstances in each case. ¶3.11- 3.20 outline the most common types of arrangements and the tax implications under each. ¶3.12 (formerly included in ¶7 of IT-75R4) has been expanded to note the exception for employer-paid or reimbursed education-related expenses that are determined to be primarily for the benefit of the employer as well as to discuss the impact of any potential commitment to repay all or a portion of an award on the taxability to the recipient. ¶3.13 (formerly included in ¶12 of IT-340R) has been added to describe the circumstances upon which a student may deduct the repayment of an award previously received in respect of an office or employment pursuant to paragraph 8(1)(n). ¶3.16 has been added to note that awards described in ¶3.14 will be considered a repayable award if the student is committed to repay all of a portion of the scholarship or bursary in the future under certain circumstances. ¶3.17- 3.20 (formerly included in ¶9 of IT-75R4) have been expanded and substantially amended to distinguish the tax implications arising with respect to employer-provided scholarship or bursary awards to family members of employees in arm’s length or non-arm’s length situations, and in respect of elementary and secondary or post-secondary education. ... In particular ¶3.28- 3.30 has been added to discuss the circumstances in which an award may be considered employment income of the recipient. ... Subparagraph 56(1)(r)(v) was added by 2009, c. 2, s. 13(2), applicable to the 2008 and subsequent tax years. ¶3.81 has been added to describe the taxation of certain assistance received by an individual in connection with their participation in an employment-related activity, in line with various CRA interpretations on the subject matter. ¶3.84- 3.85 have been added to note that certain payments may be considered social assistance under paragraph 56(1)(u) or a scholarship or bursary under paragraph 56(1)(n) depending on its primary purpose, in line with CRA interpretations and jurisprudence. ¶3.87 (formerly ¶41 of IT-75R4) has been revised to reflect the amendment to Article XX of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital pursuant to the coming into force of the Fifth Protocol. ...

Slide 9 Gift certificates and gift cards are always taxable as they’re considered near cash. ... A gift card or gift certificate to a movie theatre is not considered an event ticket. ... We do not provide a threshold amount for what is considered to be nominal value. ...

At this point, both the basic services and the number and kinds of additional services provided for, or made available to, tenants must be considered. ... For purposes of this paragraph and 12 above, to be considered "actively engaged in the business" of a partnership, a partner would normally be expected to contribute time, labour and attention to that business to a sufficient extent that such contributions would be a determinant in the successful operation of the business. ... Whether the renting of real property by an individual is a business or not, the depreciable property (ie. a building other than a building of Class 31 or 32) is considered a "rental property" for purposes of capital cost allowance. ...

Shares are considered to be "taken up" at the time of payment if this occurs before the period of acceptance expires and there is no indication that the offeror acquired the usual ownership rights before that time. ... A purchaser's right to dividends, voting rights and right to a return of capital in the event of the corporation's dissolution are considered to be important factors in determining beneficial ownership. ... As long as such restrictions can reasonably be regarded as being for the protection of the vendor's right to collect the sale price, they are not considered significant in determining beneficial ownership. ...

An officer or employee of a Crown corporation or agency who is determined to be an "officer or servant" of Canada or a province for purposes of paragraph 250(1)(c), and who is on an approved leave of absence from his or her office or employment, may be considered to be an "officer or servant" of Canada or a province during the period of absence if the relevant employment statute provides that an officer or employee is considered to remain a member of the public service during an approved leave of absence. ... This comment was considered to be potentially misleading, as there are in fact many situations in which it is either necessary (e.g., when earning Canadian employment income) or beneficial (e.g., to obtain a refund of certain withholding taxes) for a non-resident to file a Canadian income tax return. ¶ 6 is revised to reflect the importance of distinguishing between factual and deemed residence and to otherwise be more consistent with IT-221R3, Determination of an Individual's Residence Status. ¶ 7 is revised to provide updated contact information for obtaining assistance from the CCRA in determining whether an officer or employee of a Crown corporation or agency is an officer or servant of Canada for purposes of paragraph 250(1)(c) of the Act. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...

Ruling Given Based on the facts set out above, the amount paid upon the signing of a merchandising agreement is considered to be “an amount in return for the promotion of the particular property by the particular registrant”. ... Ruling Given Based on the facts set out above, the allowance given to display Manufacturer A’s trademark on the packaging of the frozen pie shells is not considered to be a qualifying allowance for purposes of section 232.1. ... Ruling Given Based on the facts set out above, the allowance given to not stock a competing manufacturer’s product is considered to be “an amount in return for the promotion of the particular property by the particular registrant”. ...

For the purposes of the dual flight time and solo flight time, the student is considered by the Department to be under instruction and direct supervision. ... For the purposes of the build-up flight time, the student is not considered by the Department to be under instruction and direct supervision. ... The 90 hours build-up time is not exempt under section 8 of Part III of Schedule V to the ETA since the student is not under instruction and direct supervision while completing the 90 hours build-up time (2) Airline Transport Pilot Licence The following flight time must be completed, pursuant to the federal legislation, in order for an individual to obtain an Airline Transport Pilot Licence: Solo flight time 625 hours Build-up flight time 875 hours The 625 hours of solo flight time is considered by the Department to be an exempt supply where all other requirements of section 8 of Part III of Schedule V to the ETA are met. ...