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Should it not be feasible to provide these benefits under the base plan, the Minister may consider accepting the supplemental plan for registration, if the primary purpose of paragraph 8502(a) and the permissible benefits under paragraph 8502(c) are met when provisions of the base plan and supplemental plan are, for testing purposes, considered as one provision. ... The Minister will give such approval only if it is not feasible to provide the supplementary benefits under the base plan, or if currently registered plans would fail to qualify for registration if considered on their own. ... Subsection 8501(6.1) of the Regulations applies where: Member contributions under a DB provision are determined by reference to the actuarial liabilities under the plan; The contributions cannot reasonably be considered to be in respect of the member’s benefits; The contributions are made pursuant to an arrangement approved by the Minister; and The main purpose of the arrangement is to ensure that the plan is adequately funded. ...

For example, if a leave of absence from January 1, 2013, to December 31, 2013, is considered to be a qualifying period, any subperiod, such as November 1, 2013 to November 30, 2013, would not be considered a qualifying period. ... While the employee is on a leave of absence and receives the deferred salary, the employee’s compensation will be considered to be the amount that would have been paid had the employee not taken the leave. ...

A stop between two legs of a journey that is 24 hours or less is not considered to be a stopover. However, a stop of more than 24 hours between two legs of a journey will generally be considered a stopover where two or more tickets or vouchers are issued for the legs of the journey. ... Therefore, each ticket has to be considered separately to determine whether GST or HST applies. ...

., the “owner”) is considered to have sold the goods to the purchaser. ... Services provided by auctioneers An auctioneer who has made a sale of goods by auction is not considered, except in limited circumstances, to have provided the owner with services related to the sale of the goods. ... Generally, a service is considered to be related to the sale of goods if both of the following requirements are met: The service provided to an owner relates directly to the sale of the goods by auction and not simply to the goods themselves. ...

However, if the taxpayer's legal representative applies in writing within that period to the Director of the local Revenue Canada tax services office, an extension of the period to what is considered reasonable in the circumstances may be granted. ¶ 5. ... If a gift is described in two or more of the categories of "total charitable gifts," "total Crown gifts," "total cultural gifts" or "total ecological gifts" made after February 27, 1995, it will be considered in the following order: a cultural gift, an ecological gift, a Crown gift, and a charitable gift. ¶ 8. ... 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. ...

A financial institution (FI) would generally be considered to be an SLFI throughout a reporting period in a fiscal year that ends in a particular taxation year of the FI if it is an LFI described in any subparagraphs 149(1)(a)(i) to (x) at any time during the particular taxation year, and the FI has a permanent establishment in a participating province and a permanent establishment in any other province, at any time during the taxation year. ... Insurance companies and fraternal benefit societies that are registered federally or provincially are generally considered to be LFIs. ... Person whose principal business is the lending of money or the purchasing of debit securities or a combination thereof – A person that carries on business principally as a finance company, acceptance company, factor, venture capitalist, or a loan, mortgage or investment company is considered to be an LFI. ...

. ¶1.31 has been modified for clarity by replacing the words “sets out the deemed dispositions which are not considered” with the words “provides that certain dispositions and acquisitions of property that are either deemed to be made by certain provisions of the Act or made in the course of certain rollover transactions are not dispositions or acquisitions”. ¶1.39 has been modified to improve readability by adding the words “paid by the partnership” immediately after the words “of the total foreign taxes” in the third sentence. ¶1.39.1 has been added to take into account the rules regarding artificial foreign tax credits generators under subsections 126(4.11) to (4.13) as enacted by S.C. 2013, c. 34 (formerly Bill C-48), s. 267(4). ... The reference to resource royalties was removed from the discussion of taxes in general since they may be a payment for a specific right or privilege, or may be part of a regulatory scheme and moved to the discussion of examples of what will not be considered an income or profits tax, to address the situation where they may be structured as a tax. ¶1.6 (formerly included in ¶5 of IT-270R3) now includes an additional bullet to reflect the operation of subsection 126(4). ¶1.7 (formerly included in ¶5 of IT-270R3) has been revised to reflect the primacy of Canadian law for characterizing a transaction, and calculating the income for the purposes granting a foreign tax credit in accordance with the language of section 126. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

If you lived outside Canada on December 31, 2002, but maintained residential ties with Canada, you may be considered a factual resident of a province or territory. ... However, this may not apply if you were a factual resident who, under a tax treaty, is considered to be a resident of another country. ... Deemed resident- You are a deemed resident for tax purposes if you did not establish residential ties in Canada, but you stayed here for 183 days or more in 2002 and, under a tax treaty, you were not considered a resident of another country. ...

A survey of this size will yield results which can be considered accurate to within +/- 2.45 percentage points, 19 times out of 20. ... Experiences with online filing and services are very commonly used to file income taxes and are considered to be a significant improvement from paper-based filing experiences. ... Some find the Agency difficult to deal with and considered them adversarial in some instances. ...

An early payment discount to which section 161 applies is not considered to be a reduction of consideration. 10. A reduction in consideration is not considered to have occurred if the goods are sold back to the original supplier. To be considered a reduction of consideration, it must be evident that the goods are being returned to the supplier rather than being sold to the supplier. ...