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The interest or income amount paid to a DSLP participant in a year during the Deferral Period is considered employment income and must be reported on the employee's T4 slip. ... Such amounts paid to the Participant will be considered employment income for the purposes of the Act and will be reported on the Participant's T4 supplementary and shall be subject to tax withholdings. 12. ... Such amounts paid to the Participant will be considered employment income for the purposes of the Act and will be reported on the Participant's T4 supplementary and shall be subject to tax withholdings. 15. ...

LossCo may still be considered to be controlled by the same group of individuals as noted in Fact 2 (i.e. ... Presumable, it is unlikely that a ABIL would be considered a loss from carrying on a business. ... Accordingly, an amount received by the employee on account of his "retirement" would not be considered a retiring allowance. ...

If an Indian carries on a business and substantially all of the business would be considered exempt but an incidental part of that business could otherwise be considered taxable, the entire income from that business will be exempt. ... Re: Indian Living On The Reserve Has Revenue Canada considered the issue of temporary residences in this regard? ... In these cases, will the Indian still be considered to live on-reserve? ...

(E) Whether any income of the trust that is not subject to 75(2) will be considered payable to the First Nation and thus deductible pursuant to 104(6). ... (C) The amounts would not be considered income from a source within the meaning of paragraph 3(a) of the Act. ... To the best of your knowledge, and that of the First Nation, none of the issues involved in the ruling request is: (a) in an earlier return of the First Nation or a related person, (b) being considered by a tax services office or taxation center in connection with a previously filed tax return of the First Nation or a related person, (c) under objection by the First Nation or a related person, (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired, or (e) the subject of a ruling previously considered by the Directorate in respect of the First Nation or a related person. ...

Position TAKEN Unitholders are not considered to have disposed of their units because of the addition of XXXXXXXXXX new XXXXXXXXXX or the reclassification of the units from one XXXXXXXXXX to another XXXXXXXXXX units of the same fund. ... We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons with the exception of ruling 981804. ... Existing unitholders of a Fund will not be considered to have disposed of their units by virtue only of the implementation of the proposed transaction described in 15 above. ...

The First Nation will be considered to be a Canadian municipality for purposes of paragraph 118.1(1)(d) and subparagraph 110.1(1)(a)(iv), and will therefore be able to issue receipts for charitable gifts. ... That, for the purposes of the various income tax conventions that Canada has negotiated with other jurisdictions, The First Nation is to be considered a political subdivision or local authority of Canada. ... Generally speaking, though, it is our view that a First Nation that qualifies as a municipality for purposes of the Income Tax Act would be considered a local authority for purposes of international tax conventions, while a First Nation that does not qualify for exemption pursuant to paragraph 149(1)(c) would likely not be so considered. ...

Qualifying organizations in the XXXXXXXXXX shall be considered first. 20. ... Qualifying charities in the XXXXXXXXXX shall be considered first. 25. ... None of the members of Entity3 and Entity4 will be considered to have realized a capital gain as a result of the amalgamation of Entity3 and Entity4, as the case may be. ...

Is the rent received by a Homeowner under the Program considered a source of rental income? ... (footnote 6) Finally, provided that a Homeowner’s rental activity is considered a source of income under the Act, it is our view that, if rental losses are incurred, the rental losses should not be denied. ...

In general, if two housing units can be enjoyed and ordinarily inhabited separate from each other without access to the other (that is, if each unit is a self-contained unit with its own entrance, kitchen and bathroom), in our view, they will be considered separate housing units for purposes of the PRE. ... (footnote 8) Nevertheless, the principal residence designation can still be made and the PRE can be claimed with respect to the housing unit that the Homeowner resides in, provided all other conditions for the housing unit to be considered a principal residence are otherwise met. ... Concerning the PRE, the Secondary Suite will generally not be considered to be a principal residence of the Homeowner since it is a separate housing unit that will generally not meet the ordinarily inhabited requirement as it continues to be rented. ...

Properties of a group are considered identical if each property in the group is the same as all the others. ...