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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. ...

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. ...

If, however, the wheat is exchanged for a new refrigerator for the taxpayer's house, the value of the refrigerator would be considered a personal or living expense and not deductible by virtue of paragraph 18(1)(h). ... An amount received or receivable (depending on the method regularly followed in computing income) by a taxpayer in the business of farming as compensation, under statutory authority for the forced destruction of livestock (such as under the Animal Contagious Disease Act), is considered to be income. ... The sale of the actual quota by a farmer would be considered to be the disposition of an eligible capital property. ...

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 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. ...

If so, what are international students generally considered as? Subject matter expert: Yes, there are. ... In this situation, you'd be considered a deemed non-resident. For more information on tax treaties, go to www.cra.gc.ca/treaties. ... Subject matter expert: When you are considered a resident of Canada for tax and benefit purposes, you have to report your income from all sources, both inside and outside of Canada, and you have the right to certain credits and benefits. ...

Products labelled as "meal replacement" or as "nutritional supplement" that meet the requirements of the Food and Drugs Act and Regulations are considered to be basic groceries. ... Although these products may contain some essential nutritional elements, they are not considered to be basic groceries. ... The product is compared to other products that are not considered to be a food, beverage or ingredient. ...

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. ...

Associated persons A particular corporation is considered to be associated with another corporation if they are considered to be associated under subsections 256(1) to (6) of the Income Tax Act. ... Partnerships and trusts Under the Excise Act, a person is considered to be associated with: (a) a partnership, if the person and all other persons associated with the person are entitled to more than half of the partnership’s total profits, or would be entitled to more than half of the total profits if the partnership had profits; or (b) a trust, if the total of the values of the interests held by the person and all other persons who are associated with the person is more than half of the total value of the interests in the trust. Association with a third person A person is also considered to be associated with another person if each of them is associated with the same third person. ...

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. ...

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. ...