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.- Q.54-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Prepaid expenses relating to an active business of the corporation could be considered as an asset used principally in an active business provided that their amount is reasonable, having regard to all the circumstances, and they were incurred in the normal course of the business. ...

HQR000265-- summary under Subsection 272.1(2) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(2) GST on cost incurred in acquiring interests in a limited partnerships would not be eligible for tax credits given that "where a member of a partnership acquires or imports property or services related to the raising of funds that the member will use to acquire an interest in a partnership, such property or services will not be considered to have been acquired or imported for consumption, use or supply in the course of activities of the partnership. ...

The part of what otherwise would be a residential building that is leased for business use is not considered to be reasonably necessary for the use and enjoyment of the building as a place of residence. ...

29 July 1992 Memorandum (Tax Window, No. 21, p. 4, ¶2037)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Two unrelated individuals each holding ½ of the shares of a corporation will not be considered to act in concert simply because the consent of both is required before the corporation can undertake any action. ...

The non-resident would not be considered to be carrying on business in Canada provided that the contract for the sale of the compact discs to the distributor by the non-resident was concluded outside Canada. ...

September 1994)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Where a corporation's fees under service contracts are paid in advance and such funds are invested in term deposits, the term deposits could be considered to be used in its business if they satisfy RC's general requirement that the assets be really used and risked in the business, and if they have been so invested in anticipation of a possible repayment of the fees paid in advance. ...

Furthermore, in some instances, where the agreements provide for the delivery of an actual physical commodity, the supply is not a financial instrument….Therefore, the Brokers providing the services in respect of these contracts to USCO and CANCO would not be considered to be "arranging for" financial services and consequently, the supplies provided by the Brokers would not be financial services. ...

14 July 1999 Memorandum HQR0001244-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) target circular costs eligble "Property or services acquired... by a corporation in fulfilling obligations under a securities or corporations Act in producing circulars for shareholders concerning takeover bids, would generally be considered to have been incurred for the purpose of making supplies for consideration in the course of the corporation's endeavour.... ...

It is also considered that the joint ownership of a home by a taxpayer with her spouse after January 1, 1990 will not result in disqualification if subsequent to that time she was separated from her spouse and did not inhabit the house, as referred to in s. 146.01(2)(a.1). ...

September 1994)-- summary under Subsection 22(1) Summary Under Tax Topics- Income Tax Act- Section 22- Subsection 22(1) In considering a situation where a corporation had two divisions, one of which did printing and the other which did photo typesetting, and all the assets of the first division were sold to another corporation which continued the operation in the same manner and under the same name, RC stated that "the fact that the corporation that has acquired the assets used in the printing division can be considered to be carrying on a separate business does not mean that the vendor corporation was operating its two divisions in the form of two separate businesses. ...