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The following are examples of services that are considered to be in respect of real property for purposes of Part V of Schedule VI: (a) services physically performed on the real property (e.g., construction and maintenance); (b) services that enhance the value of the real property, affect the nature of the real property, relate to preparing the real property for development or redevelopment, affect the management of the real property, or affect the environment within the limits of the real property (e.g., engineering, architectural services, surveying and subdividing, management services, security services); (c) services related to; (i) the transfer or conveyance of the real property or the proposed transfer or conveyance of the real property (e.g., real estate services in relation to the actual or proposed acquisition, lease or rental of the real property, legal services rendered to the owner or beneficiary or potential owner or beneficiary of real property as a result of a will or testament); (ii) a mortgage interest or other security interest in the real property; or (iii) the determination of the title to the real property. ...

…[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. ...

Where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. ...

CRA responded: Forco's issuance of shares…would result in Forco being considered to have "sold an investment in itself"…. ...

Since the management company has operational control, the management company would be considered to be a participant and operator of the joint venture…. ...

Every combination of eligible corporations or eligible Canadian partnerships whose names appear in Part A of the form (and on any attached page) is considered to have made the election. ...

[B] paragraphs (g) and (h) of subsection 266(2) require a receiver to file outstanding returns for reporting periods which occurred prior to the receiver's appointment, but only insofar as the outstanding returns "relate" (in the case of paragraph (g)) or "can reasonably be considered to relate" (in the case of paragraph (h)) to the receiver's relevant assets, as though the receiver had been acting as receiver of the insolvent during the reporting period of the insolvent for which the return was not filed. ...

If for any reason the transferee corporation does not obtain, under the applicable corporate legislation, the necessary authorization for the issuance of the shares, the election under subsection 85(1) will be considered to be invalid. ...

4 December 1995, November TEI Round Table, Q. 4, 953042-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) In response to a question as to whether compensation payments made under a securities loan from a related non-resident corporation should be viewed by as either "any payment for the use of or for the right to use in Canada any property" (under s. 212(1)(d)(i)) or "any payment that was dependent on the use of or production from property in Canada" (under s. 212(1)(d)(v)), CRA responded: Where the borrower pays the non-resident lender a fee ("lending fee" or "borrowing fee") for entering into the arrangement, it is our view that the fee would generally be considered to be for the use of or the right to use property in Canada and as such would be subject to withholding tax pursuant to subparagraph 212(1)(d)(i) of the Act. ...

In finding that the "optioning" under the agreement by the Optionor was a provision of natural resource rights in respect of an unproven property which s. 162(2)(a) deemed not to be a supply, CRA stated: Strictly speaking, an option to acquire something is not necessarily the same as acquiring the thing itself and an option to acquire something is generally considered to be a supply. ...