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Consequently, the partnership would not be considered an FA of CRIC 1 and FA 1’s interest in the partnership does not qualify as EP. ... Under partnership law in common-law provinces, all members of a partnership are considered to be carrying on any activity carried on by the partnership [fn 166: Robinson Trust … 98 DTC 6065… nos. 9722815… 2000-0059145,… 2001-0090655;… 2002-0149977,…and 2001-0070605,…See also 9636835…confirmed… 2012-0453991C6 (f)…after this principle was challenged in the case of Quebec civil-law partnerships in Laval (Ville de) c. ...

A common identifying feature (such as being non-residents, as in Silicon Graphics) is insufficient to establish such a connection. 2) The common connection might include but is not limited to a voting agreement, an agreement to act in concert, or a business or family relationship. 3) Beneficiaries may share a mutually beneficial objective, such as maximizing the value of their investments in the trust, without being considered a group. 4) Beneficiaries can participate in modern corporate or commercial steps, such as granting a proxy or participating in a reorganization of the trust (for example, a fund merger pursuant to section 132.2), without being considered a group. 5) Whether the beneficiaries know, can identify, or communicate with each other is relevant in determining whether they are a group. ...

It might have been considered that the share value corresponding to the tax withholding amount was to be treated as cash or quasi-cash resulting effectively from the disposition of rights under s. 7(1)(b) (or (b.1)), so that the corporate tax deduction on such portion would not be prohibited by s. 7(3)(b). ... S 7(3)(b) precludes deduction for in-bound recharge (p. 19) The payment of recharges (respecting when a subsidiary reimburses its the parent for the cost of stock options or share awards granted by the parent to the subsidiary's employees) is not considered to result in the conferral of a benefit on the parent. ...

The answer in many statutory contexts is that the set of transactions must bear a family resemblance to those that Parliament could reasonably be considered to have had in mind in invoking the series concept as a means of anti-avoidance. ... The court would then attempt to ascertain whether the transactions carried out by the taxpayer bore a sufficient family resemblance to that stylized set of transactions or events to be considered a series for the purposes of that particular statutory invocation of the term. ... That being said, in our view, the option grant should not form part of the series for a more fundamental reason—namely, that the option grant does not bear any family resemblance to the types of transactions that Parliament can reasonably be considered to have had in mind when it enacted subparagraph 88(1)(c)(vi).... ...

The loss business was the sale of an electronic shelf labelling system used to register and display prices on grocery shelves, but did not extend to the use of that technology in other industries in the absence of any evidence that other applications had been considered by the Lossco prior to the acquisition. ... Integration of loss business into that of acquiror (p.9:16) Where the loss business is integrated into the business of the acquiror, it is unclear whether the similar business test even has to be considered. ... The court held that the fact that it was not necessary to create a separate division to operate the loss business activities was considered evidence of the similarity between the loss business and the integrated business. ...

The IA definition provides that the word "corporation" "does not include a partnership that is considered to be separate legal entity under provincial law."… [T]he better view is that the IA definition confirms that a partnership that is considered to be a separate legal entity should nevertheless be considered to be a partnership. … [T]here is a strong argument that the IA definition applies for greater certainty to ensure that LLLPs and LLPs are not treated as corporations. Further, the phrase "a partnership which is considered to be a separate legal entity under provincial law" does not necessarily limit the application of the IA definition to partnerships governed by provincial law. ...

", International Tax Planning, 2011, p. 1136-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Contrary to a CRA suggestion "there does not appear to be any Canadian authority requiring that a foreign entity 'issue capital stock' in order to be considered a 'corporation'.... ...

Broadhurst, "Financing by Non-Residents", 1992 Corporate Management Tax Conference Report, pp. 9:10-9:18-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Discussion of whether a non-resident purchaser of accounts receivable would be considered to be carrying on business in Canada. ...

Joint Committee, "Avoidance of Tax Debts", 5 April 2022 Joint Committee Submission-- summary under Paragraph 160(1)(c) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1)- Paragraph 160(1)(c) Exclusion of s. 251(5)(b) rights There should not be considered to be non-arm's length status by virtue only of rights described in s. 251(5)(b). ...

Questions of natural justice are considered to be questions of law and reviewed on the same standard:…[fn 24: Waycobah First Nation... 2010 FC 1188..., aff'd 2011 FCA 191.... ... See also Cogesco... 2013 FC 1238 at paras 18-20... and 3500722 Canada... 2008 FC 554....] the Federal Court allowed the application for judicial review on the basis that the court was unable to determine on the record whether the CRA considered certain facts that the court considered relevant: … In the early years of the administration of subsection 220(3.1), it was more common for the Federal Court to find a lack of independence within the CRA during the process of subsequent reviews. ...