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IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa" 16 September 19864-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The allocation of the cost of real estate to inventory in the taxpayer's accounting records will be considered to represent prima facie evidence that the real estate was initially acquired with the intention of reselling it at a profit at a propitious time. ...

4 June 1993 Memorandum (Tax Window, No. 32, p. 9, ¶2602)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee is dismissed, receives an arbitration award and is reinstated to his former position, any amounts received as part of the settlement which are in respect of out-of-pocket expenses incurred by the individual will be considered to be a taxable benefit. ...

As the sites could not be considered to be accessible and serviced throughout the year, the park was not a residential trailer park. ...

"Part I.3 Tax- Deferred Revenue")-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Generally, where an amount of expenses is paid before it is due by one corporation to another corporation that is not a "financial institution", and reported on the annual financial statements as a deferred charge it will be considered to be an advance pursuant to s. 181.2(4)(b). ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Subsection 214(7) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(7) convertible premium taints all other interest The amount considered to be repaid on the conversion of a convertible debenture generally will be the stated capital of the shares issued. ...

June 2012 Draft GST/HST Technical Information Bulletin B-103, "Harmonized Sales Tax- place of supply rules for determining whether a supply is made in a province"-- summary under Section 28 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 28 Includes Example 120 (the provision of lighting and other special effects at a gala event event in Quebec is considered to be services performed at the convention centre where the gala takes place). ...

1 August 1991 Memorandum (Tax Window, No. 7, p. 3, ¶1381)-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Among the factors which RC would consider relevant to whether the amount of the premium may reasonably be considered to relate to the outstanding debt, are whether other assets have been pledged to the lender, whether the lender requires collateral in excess of the loan balance, and whether the assets pledged as security are difficult to value. ...

For example, if you pay the property taxes, have the right to alter the land, control entry or access to the property, or pay insurance coverage, you may be considered to have possession of the property. ...

.- Q. 11-- summary under Subsection 66.7(3) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(3) Where there is an acquisition of control of Company A thereby causing Company A's resource pools to be successored, and Company A subsequently transfers its resource properties to a partnership electing a nominal amount under s. 97(2), Company A's proportionate share of production revenue allocated to it by the partnership will be considered to be income under, for example, s. 66.7(3)(b)(i)(C) which is eligible for successor pool deductions. ...

17 July 1995 Headquarter Letter File 11635-3-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply When a non-resident sells discs in Canada under a consignment arrangement with a Canadian distributor, the fact that there is a sale from the non-resident to the distributor simultaneous with the sale by the distributor to a Canadian consumer does not necessarily cause the initial contract to be considered to be concluded in Canada. ...