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The holder is considered to have disposed of the contract or the deposit immediately before the time that the TFSA ceased to exist for an amount equal to the FMV of all the property held in the TFSA at the time of death. After the holder's death, the deposit or annuity contract is considered to be a separate contract and is no longer considered as a TFSA. ... Management fees Management fees related to a TFSA trust and paid by the holder are not considered to be contributions to the TFSA. ...

The newly designated shares (Class A above) are considered, for all purposes of the Act, to be the same property as the original common shares and to have been acquired at the same time and for the same cost as the original common shares. ... IT-448 entitled, Dispositions- Changes in the Terms of Securities and the Special Release thereto discuss the factors that are considered in determining whether or not a disposition pursuant to paragraph 54(c) has taken place when the terms of a security have been altered. It is considered that the specific circumstances outlined in 1 above do not result in a disposition. ...

Such fees are not considered charitable donations and official receipts designed for charitable donations may not be issued for such tuition fees even though the educational institution may be a registered Canadian charitable organization as defined in paragraph 110(8)(c) of the Act. 2. The purpose of this circular is to explain two exceptions to the above rule where a portion or all of an amount paid to a school, other than a post-secondary institution or a designated educational institution (see Appendix A), may be considered as a donation. ... If such a school teaches exclusively religion and thereby operates solely for the advancement of religion, payments for students attending that school are not considered to be tuition fees but will be considered as valid donations and, providing the school is a registered Canadian charitable organization, official receipts for charitable donations may be issued for such payments. ...

" Projects designed to educate registered charities about their obligations regarding gifting to qualified donees will be considered for funding. ... Small and rural – In 2008, projects designed to address the distinct needs of small and rural charities in meeting their obligations under the Income Tax Act were considered for contribution funding. ... For 2009-2010 (April 1, 2009, to March 31, 2010), only one-year projects will be considered for funding. ...

Issue Is Corporation A considered to have made a supply of personal property that was produced by Corporation A exclusively for use in the course of activities that are not commercial activities under subparagraph 141.1(1)(b)(ii) of the Act? Comments Corporation A is considered to have made a supply of personal property that was produced in the course of its activities that are not commercial activities. ... Comments Dentist A is not considered to have made a supply of personal property that was produced exclusively for consumption or use in activities that are not commercial activities of the dental practice. ...

Rationale The right to enter the lands for the purpose of developing and excavating gravel deposits on the lands, and mining and removing the gravel is considered a supply of a right to explore for or exploit a mineral deposit. ... Rationale Since DEF has acquired the right to explore for or exploit a mineral deposit, the royalty payment that DEF makes to ABC for the purchase of the gravel is considered to be a fee or royalty charged or reserved in respect of the right to explore for or exploit a natural resource. ... Rationale DEF has acquired the right to explore for or exploit a forestry resource, and the royalty payment that DEF makes to ABC for the timber is considered to be a fee or royalty charged or reserved in respect of the right to explore for or exploit a natural resource. ...

Workers who are engaged in aquaculture (cultivation of aquatic plants or animals), silviculture (cultivation of trees) or viticulture (cultivation of grapevines) are not considered to be agricultural or horticultural workers. ... The first condition applies because even though the amount received is over $250, the value of the wood is not considered to be a cash payment. ... The cords of wood are not considered to be a cash payment. In both cases, the employment is not insurable because one of the conditions applies. ...

It has been the long-standing position of the Canada Revenue Agency (“CRA”) that, to be considered “liable to tax” for the purposes of the residence article of our treaties, a person must be subject to the most comprehensive form of taxation as exists in the relevant country. ... To clarify any ambiguity and as announced at the 2005 Canadian Tax Foundation conference, CRA agreed to undertake a review of its position regarding the level of taxation a jurisdiction must levy on a person's income before that person would be considered “liable to tax” under a tax treaty. ... It remains CRA's position that, to be considered “liable to tax” for the purposes of the residence article of Canada's tax treaties, a person must generally be subject to the most comprehensive form of taxation as exists in the relevant country. ...

When you keep a treasury bill (T-bill) until it matures, the difference between the issue price and the amount you cash it in for is considered to be interest that accrued to you. ... At the time you give the gift, depending on the type of property you give, you are considered to receive an amount equal to: the undepreciated capital cost for depreciable property; or the adjusted cost base for other types of capital property. Your spouse or common-law partner, or the trust for your spouse or common-law partner or for yourself, is considered to have bought the capital property for the same amount that you are considered to have sold it for. ...

Approval or denial of your request Factors used in arriving at the decision Where circumstances beyond your control, actions of the Canada Revenue Agency (CRA), or inability to pay or financial hardship has prevented you from complying with your tax obligations, the following factors will be considered when determining whether or not the CRA will cancel or waive penalties or interest: your history of compliance with your tax obligations; whether or not you knowingly allowed an arrears balance to exist upon which arrears interest has accrued; whether or not you exercised a reasonable amount of care in conducting your tax affairs, and whether or not negligence or carelessness has been demonstrated; and whether or not you acted quickly to remedy any delay or omission Third-party actions You are generally considered to be responsible for errors or delays made by a third party acting on your behalf for tax related matters. ... A second review request requires the following: the reasons why you disagree with the CRA's decision, e.g., not all information was considered, certain facts or details were missing or misinterpreted or not considered in their proper context; and any relevant new documents, new facts, or correspondence To maintain impartiality and transparency, the second review will not be conducted by the CRA official involved in the first review and decision. ...