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A tax credit or deduction from tax is considered to be received (and therefore included in income if it is an inducement or assistance in respect of the cost of property or an expense) at the earliest of when it is applied: to reduce a taxpayer's tax instalment payable, and to create or increase a tax refund or to reduce tax liability for a taxation year. ... In contrast to the general timing rule described above, by virtue of subsections 125.4(5) and 125.5(5), tax credits received under sections 125.4 and 125.5 are always considered to be received before the end of the taxation year to which the credits pertain. The lack of such a deeming provision in respect of other tax credits or deductions from tax does not mean that such amounts are not considered to be government assistance. ...

…[I]f for example,… a manufacturing company charged a fee for providing a loan to its customers, such a fee would be considered to be a separate fee or charge for a financial service Partnerships included 15. ... However, if a person purchases bonds on the secondary market (that is, from a person other than the issuer of the bonds or an agent thereof), the person is not considered to have lent money to the bond issuer. Cash generates bad interest Example 3 … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

Gold bullion and gold certificates (or bullion and certificates of the same precious metal) are considered... to be identical properties. Furthermore...a particular certificate and the bullion to which it relates are the same property, with the result that an exchange of a certificate for bullion or bullion for a certificate will not be considered a disposition. 7....Class X common shares of a corporation and Class Y common shares of the same corporation are the same in all respects, except that the Class X shares are voting and the Class Y shares are non-voting, and that the holders of the Class X shares are entitled to exchange them for Class Y shares.... ... [F]utures contracts for the same standard amount of the same commodity for delivery in the same month are considered to be identical. ...

This is the amount of land that is usually considered to be reasonably necessary for the use and enjoyment of the building as a place of residence. Land in excess of a half hectare is generally not considered to form part of the residential complex, unless it can be shown that such land is reasonably necessary for the use and enjoyment of the building as a place of residence for individuals. ... If a legally imposed minimum lot size exists, and this minimum was in effect on the date the property was acquired, this minimum is generally considered to be the amount of land reasonably necessary for the use and enjoyment of the building as a place of residence, even if this minimum exceeds a half hectare. ...

. … Accordingly, property leased from a lessor is generally not considered to have been acquired for income tax purposes and, as such, is not treated as capital property for purposes of the ITA or, by extension, the ETA. ... Therefore, property leased from a third party will not be considered to be capital property for GST/HST purposes, regardless of whether the lessee and the lessor have made an election under subsection 16.1(1) …. CRA noted the general principle in this regard that generally a registrant is not considered to have acquired property for ITC purposes unless ownership of the property has been transferred to it. ...

CRA responded: Usually, gross negligence penalties are not assessed where it is considered that there was a genuine misinterpretation of the ETA on the part of the registrant and it is reasonable to assume that the registrant did not know whether a particular supply was a taxable supply. Generally speaking, no penalty will be assessed where it appears that the registrant was confused about the reporting of an amount and it is the first time a penalty is being considered. However, gross negligence penalties may be considered based on the materiality of the error or where the registrant was previously advised of penalty consideration for similar conduct. ...

In finding that ITCs generally were available for the first, but not the second, type of invoice, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. Therefore, where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time).... ...

Repayment by set-off or application of dividends or bonus 1.82 A loan can be considered to have been repaid by way of set-off against a receivable of the borrower. ... Bona fide commercial loan exception 1.85 A repayment may also be considered to have been made as part of a series of loans or other transactions and repayments where the proceeds of a new loan are used to repay an existing shareholder loan. However, such a repayment will not be considered part of a series of loans or other transactions and repayments if it can be shown that the new loan was from an independent source, was received for a genuine business purpose, and was not received for the purpose of repaying the existing shareholder loan amount. ...

IT-441 dated November 29, 1979 "Capital Cost Allowance- Certified Feature Productions and Certified Short Productions"-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "A disposition of the film or tape will be considered to take place where the investor grants to a person or persons the right to distribute or otherwise exploit the film or tape in markets representing most or all of the exploitable value of the film or tape for a fixed amount of consideration or for a guaranteed minimum consideration which can reasonably be considered to be its fair market value. ...

This is not considered to result in double taxation as a benefit is only considered to arise where it cannot be demonstrated that membership is principally for the employer's advantage. ...