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For United States tax purposes, CanLP will be considered to have disposed of the shares of Canco. ... USCo is considered to earn interest from the loan and USCo and USSub are considered to have incurred a proportionate share of the interest expense payable by ULC on the loan from USCo. ... Had ULC not been considered a disregarded entity, USCo would be considered to have made an interest-bearing loan to ULC. ...

Assuming that Country X is Canada and the merger takes place as described in paragraph 2 above, (i)     Shareholder B will be considered to have alienated his shares of BCo at their tax cost  and to have acquired the shares of ACo at that cost, (ii)     alternatively, Shareholder B and ACo may Jointly elect at a higher amount (but not exceeding the fair market value of the shares of BCo) and Shareholder B will be considered to have alienated his shares of BCo at such elected amount and to have acquired the shares of ACo at that amount, (iii)     on the liquidation of BCo, BCo will be considered to have alienated all of its property at its fair market value and ACo will be considered to have acquired such property at that fair market value. 8.      ... The tax consequences under the Act to ACo and BCo of such a merger are not clear and ACo and BCo may be considered to have alienated any property that becomes a property of ABCo as a result of the merger at the fair market value of such property and  ABCo may be considered to be a new corporation that acquired such property at a tax cost equal to the fair market value thereof.  ... Assuming that Country y is Canada and that the results of the merger are as described in paragraph 5-above, (i)     Shareholder B will be considered to have alienated his shares of BCo for an amount equal- to the fair market value of the shares of ABCo received by Shareholder B by virtue of the merger, (ii)     BCo will be considered CO have alienated all of its property at its fair market value and ABCo will be considered to have acquired such property at that fair market value, and (iii)     any income or gain realized by BCo on such alienation of property will be subject to tax-in Canada. 10.      ...

Assuming that Country X is Canada and the merger takes place as described in paragraph 2 above, (i) Shareholder B will be considered to have alienated his shares of BCo at their tax cost and to have acquired the shares of ACo at that cost, (ii) alternatively, Shareholder B and ACo may Jointly elect at a higher amount (but not exceeding the fair market value of the shares of BCo) and Shareholder B will be considered to have alienated his shares of BCo at such elected amount and to have acquired the shares of ACo at that amount, (iii) on the liquidation of BCo, BCo will be considered to have alienated all of its property at its fair market value and ACo will be considered to have acquired such property at that fair market value. ... The tax consequences under the Act to ACo and BCo of such a merger are not clear and ACo and BCo may be considered to have alienated any property that becomes a property of ABCo as a result of the merger at the fair market value of such property and-Co may be considered to be a new corporation that acquired such property at a tax cost equal to the fair market value thereof. ... Assuming that Country y is Canada and that the results of the merger are as described in paragraph 5-above, (i) Shareholder B will be considered to have alienated his shares of BCo for an amount equal- to the fair market value of the shares of ABCo received by Shareholder B by virtue of the merger, (ii) BCo will be considered CO have alienated all of its property at its fair market value and ABCo will be considered to have acquired such property at that fair market value, and (iii) any income or gain realized by BCo on such alienation of property will be subject to tax-in Canada. 10. ...

Whether more than one meal allowance may be provided during a period of overtime without being considered a taxable benefit. ... Less than three times a week will generally be considered infrequent or occasional. ... Therefore, the first meal allowance received by an employee would be considered a taxable benefit since it was received after one hour of overtime. ...

The situation you describe involves the accumulation of funds for a new business and whether those funds would be considered to be used in an active business. ... Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize the business. ... Cash balances which accumulate and are then depleted in accordance with the annual seasonal fluctuations of an ongoing business will generally be considered to be used in the business, but a permanent balance in excess of the company's reasonable working capital needs will generally not be considered to be so used. ...

Principal Issues: 1) is the purchase of a unit of a partnership involved in an active business considered investment of funds for 132(6)(b)(i)? ... Issue #5 Is the writing of covered call options by a Fund considered to be investing of its funds for the purpose of subparagraph 132(6)(b)(i) of the Act? ... In general, such transactions are considered ancillary to investing or part of a wide range of investing activities. ...

Principal Issues: Whether business of a corporation is considered a specified investment business for the purposes of ss. 125(7) of the Act. ... Interpretation Bulletin IT-479R lists some of the factors to be considered in making such a determination. ... You also ask how many employees in the situation described above would be considered employed on a full-time basis in the investment business. ...

(Note- there would be no Canadian income tax liability if such a transfer is effected at a time that the employee is considered not to be resident in Canada for the purposes of the Act). 1. ... (b) If the payee is considered not to be resident in Canada at the time the pension payment is made, the comments in 5 above apply except that the rate of Part XIII tax is 15%, rather than 25%. 7. ... (b) If the payee is considered not to be resident in Canada at the time the pension payment is received, there are no Canadian income tax implications. ...

The harvesting of peat and the manufacturing and processing of compost, by themselves, are not generally considered to be farming activities. ... However, this list is not considered exhaustive. The Farming Income Guide- T4003 published by the CRA lists other activities that may be considered farming, such as tree farming, cultivating crops in water or hydroponics, Christmas tree growing, operating a wild game reserve, operating a chicken hatchery, operating a feedlot. ... In and of itself, simply buying worms for resale and/or picking and packing worms for shipment would not generally be considered farming activity. ...

Whether dealing in commodity futures contracts by a mutual fund trust would be considered "the investing of funds of the trust" for purposes of paragraph 132(6)(b) of the Income Tax Act (the "Act"). 2. Whether commodity futures contracts are considered investments that are "marketable securities" for purposes of paragraph 5000(7)(b) of the Income Tax Regulations (the "Regulations") and whether income earned on the settlement of a futures contract is considered to be "derived from" the futures contract. We are of the view that a mutual fund trust dealing in commodity futures contracts would be considered to be investing funds of the trust for the purposes of paragraph 132(6)(b) of the Act. ...