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" 31 March 2003-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Although most fundraising activities are business activities, a fundraising event generally will not be considered to "recur with such regularity and frequency that it amounts to carrying on a business" (para. 12). ...

88 CPTJ- Q.10-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits The treatment of sour gas by a gas plant is considered to be processing because there would normally be by-products that would be derived from such processing. ...

.- "Finance and Leasing"- "Interest"- "Participating Loans"-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Where participating payments are limited to a percentage of the principal amount reflecting commercial interest rates, then the amounts can be considered to be referable to the principal amount. ...

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1570)-- summary under Class 28 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 28 An acquisition of equipment will not be considered a "major expansion" where it increases or recovery at a mine by more than 25% but there is no mill. ...

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1570)-- summary under Class 41 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 41 An acquisition of equipment will not be considered a "major expansion" where it increases recoveries at a mine by more than 25% but there is no mill. ...

.- "Finance and Leasing"- "Interest"- "Purchase of Common Shares"-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Interest on money borrowed in order to purchase common shares normally is considered to be deductible on the basis that the potential return to the common shareholder may exceed his borrowing cost. ...

Income Tax Technical News, No. 34, 27 April 2006 under "Delaware Revised Uniform Partnership Act"-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Delaware LPs with separate personality are not corps Partnerships formed under the DRUPA or DRULPA normally would be considered to be partnerships for purposes of the Act. ...

.- Q26-- summary under Subsection 186(4) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(4) A corporate beneficiary of a trust will not be considered for purposes of s. 186(4)(b) to own shares held by the trust notwithstanding that the trust has made a designation under s. 104(19) in respect of taxable dividends paid on the shares. ...

IT-464R, para. 8-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) "When a tenant makes improvements and alterations to leased property and subsequently abandons them, they are not considered to have been acquired by the landlord as a gift, bequest or inheritance under paragraph 69(1)(c). ...

IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Where the treaty does not contain a specific article on management or administration fees, such fees paid to the non-resident will, to the extent they are reasonable, be considered to be covered by the business profits article. ...