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23 April 1990 Memorandum (September 1990 Access Letter, ¶1412)-- summary under Subsection 2900(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2900- Subsection 2900(2) The concession in IT-151R3, para. 11 (that normal year-end accruals would be considered to have been "paid") is a practical but minor concession made to assist district offices in processing refundable investment tax credit claims. ...

7 November 1992 Memorandum (Tax Window, No. 27, P. 21, ¶2354, October 1993 Access Letter, p. 478)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) Ontario's super allowance for scientific research and current cost adjustment is not considered to be government assistance, incentives or tax credits for the purposes of any of ss.13(7.1), 127(9), 12(1)(x), 37(1)(d) and 53(2)(k). ...

22 November 1991 Memorandum (Tax Window, No. 13, p. 9, ¶1608)-- summary under Paragraph 5907(2)(j) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(2)- Paragraph 5907(2)(j) In the absence of persuasive evidence, charitable donations, political donations and penalties will not be considered to be deductible. ...

P-032, 20 July 1992-- summary under Commercial Activity Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Commercial Activity "It is the Department's position that the provision of management services by a holding corporation to a subsidiary corporation for nil consideration is considered to be a commercial activity". ...

.- Q. 10-- summary under Short-Term Preferred Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Short-Term Preferred Share A share is considered to be "convertible" or "exchangeable" for purposes of paragraph (b) where either the holder or the issuing corporation has the option to convert or exchange. ...

However, where the employer had a contractual obligation to pay a bonus annually, but the bonus for the period had not been declared as of the date of death, the amount would be considered to be periodic remuneration taxable under s. 70(1). ...

However, where the partnership was primarily formed to avoid the application of s. 18(4), the application of s. 245(2) will be considered. ...

Profit- Swaps All amounts payable or receivable pursuant to an interest rate swap agreement will be considered to be on account of income and will be included in or deductible from the income of the taxpayer pursuant to s. 9. ...

Repairs or Running Expense Software is considered to be a capital asset where its useful life is anticipated to last beyond one year. ...

.- Q.51-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business Each full-time employee of a particular partnership will be considered to be a full-time employee of each corporate partner. ...