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For conversions of contributed surplus into paid-up capital occurring after December 20, 1992, subsection 84(11) limits the amount of contributed surplus that can be considered to have arisen under subparagraph 84(1)(c.3)(ii) (described in (b) above). ... 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. ...

The creditor is neither the beneficiary of the policy nor the policyholder and would not be entitled to include the proceeds in its capital dividend account because the amount it receives would not be considered to be proceeds of a life insurance policy. ... 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. ...

New ¶ 9 provides examples of expenses which are considered supplies for purposes of subparagraph 8(1)(i)(iii), while new ¶ 10 provides examples of expenses which are not considered supplies. ...

(f) Identification of Payments with Amounts Unpaid Where a particular expense remains unpaid and is made up of several unpaid amounts of the same nature, any payments received for these unpaid amounts are considered to apply first to the oldest amount outstanding unless the facts clearly indicate otherwise. ... 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. ...

" Act " means the Excise Tax Act; " associated persons " persons are considered to be associated in the following circumstances: (a) a particular corporation is associated with another corporation if, by reason of subsections 256(1) to (6) of the Income Tax Act, the particular corporation is associated with the other corporation for the purposes of that Act; (b) a person other than a corporation is associated with a particular corporation if the particular corporation is controlled by the person or by a group of persons of which the person is a member and each of whom is associated with each of the others; (c) a person is associated with: (i) a partnership if the total of the shares of the profits of the partnership to which the person and all other persons who are associated with the person are entitled is more than half of the total profits of the partnership, or would be more than half of the total profits of the partnership if it had profits; and (ii) a trust if the total of the values of the interests in the trust of the person and all other persons who are associated with the person is more than half of the total value of all interests in the trust; and (d) a person is associated with another person if each of them is associated with the same third person; " calendar quarter " means a period of three months beginning on the first day of January, April, July or October in each calendar year; " Departmen t" means the Department of National Revenue, Customs and Excise; " fiscal month " of a person means a period that is determined under section 243 of the Excise Tax Act to be the fiscal month of the person; " fiscal quarter " of a person means a period that is determined under section 243 of the Excise Tax Act to be the fiscal quarter of the person; " fiscal year " of a person means (a) where the person has made an election under section 244 of the Excise Tax Act that is in effect, the period that the person elected to be the fiscal year of the person, and (b) in all other cases, the taxation year of the person; " Minister " means the Minister of National Revenue; " person " means an individual, partnership, corporation, trust or estate, or a body that is a society, union, club, association, commission or other organization of any kind; " prescribed " means (a) in the case of a form, the information to be given on a form or the manner of filing a form, prescribed by the Minister, and (b) in any other case, prescribed by regulation or determined in accordance with rules prescribed by regulation; " registrant " means a person who is registered, or who is required to apply to be registered, under sections 240 and 241 of the Excise Tax Act; " reporting period " of a person means the reporting period of the person as determined under sections 245 to 251 of the Excise Tax Act; " taxation year " of a person means (a) where the person is a taxpayer within the meaning of that term in the Income Tax Act, the taxation year of the person for the purposes of that Act, and (b) in any other case, the period that would be the taxation year of the person for the purposes of that Act if the person were a corporation. ... Pursuant to subsection 280(4) of the Act, penalty and interest payable in respect of instalments not paid by the due date of the net tax on account of which the instalment was payable will be considered to be an amount of net tax not remitted and will, therefore, continue to be subject to penalty and interest until paid. 23. ...

Where an unincorporated organization is separated into a number of branches or divisions, each of these branches or divisions could, if they are sufficiently autonomous, be considered separate persons for GST/HST purposes, and therefore, except for those that are small suppliers, each would be required to register for the GST/HST. ... A branch or division may be considered a person if: the branch or division may sue and be sued in its own name; the branch or division is capable of holding property in its own name; the parent body is not liable for the debts and obligations of the branch or division, and the branch or division is not liable for the debts and obligations of the parent body or of any other branch or division; the branch or division has the capacity to contract in its own name; the branch or division has its own constitution (or charter) and by-laws; the branch or division has its own board of directors and does not have, to any significant extent, directors, officers or employees that are common with the parent body or any other branch or division; the branch or division enjoys a considerable degree of autonomy in its day-to-day operations (e.g., financial resources allocation, program development, staffing, payroll); the branch or division raises most of its revenues as opposed to receiving funding from the parent body (e.g., the branch or division is self-sustaining financially); the accounting activities of the branch or division are separate from those of the parent body and other branches or divisions (e.g., separate books and records, financial statements, bank accounts, etc.); the financial and/or fiscal year of the branch or division is different from the financial and/or fiscal year of the parent body and other branches or divisions; the members of the branch or division are different from the members of the parent body and other branches or divisions; persons do not automatically become members of the parent body or of another branch or division by becoming members of the branch or division and vice versa; and the branch or division has its own distinct seal. ...

An agent is considered to be an extension of the principal, and as a result, the actions of the agent are generally regarded as being those of the principal. ... Does the "agent" separate from its own monies any money received or paid out which is considered to belong to the "principal"? ...

Further, according to general legal principles, a corporation that is not incorporated in Canada may still be considered a resident of Canada, if the central management and control of the activities of the corporation is exercised in Canada. ... Appendix A Satisfactory evidence as proof of non-residence in Canada The following example of written documentation, to be kept on file, will generally be considered satisfactory to the Minister of National Revenue as certification that the person to whom the supply is made is not resident in Canada: (a) In the case of a non-resident individual: I,_________________________, (name and complete address of individual) certify that I am not resident in Canada for purposes of the Excise Tax Act. ...

Amalgamation s 271 If two or more corporations amalgamate, the successor company is a new entity and is considered to be a person separate and distinct from each of its predecessor corporations. ... Generally, when a person ceases to be a registrant, any property held by the person for consumption, use or supply in a commercial activity is considered to have changed to non-commercial use. ...

To be considered a major addition, the addition must change the character of the previous complex to such a fundamental extent that the original building and the addition together essentially form a newly constructed residential complex. ... For example, if the renovation of a unit is sufficiently extensive to be considered a “substantial renovation”, the GST/HST new housing rebate will be available either to the qualifying purchaser of such a home from the “builder” or to a qualified individual if the individual carried out the renovation for his or her use as a primary place of residence or engaged a contractor to do the renovation. ...