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(A similar question was asked at the CPTS Roundtable in 1988, and the response was that the matter was before the courts: could Revenue Canada please cite the relevant case if the matter has in fact been considered by the courts?) ...

In addition, it would have to be considered whether the general limitation on deductibility contained in paragraph 18(1)(a) of the Act or a specific prohibition, e.g., paragraph 18(1)(m) of the Act with regard to royalties, was applicable with regard to any such expenditures. ...

DEPARTMENT'S POSITION Where a vehicle (employee-owned or employer-provided) is regularly required to be used during business hours in the carrying out of employment duties, the value of the parking facility that is provided by the employer for that vehicle is not considered to be a taxable benefit to the employee to whom it is assigned. ...

A period abroad is considered to commence on the first day an employee performs his duties of employment outside Canada and to end with the last day he ceases to perform the duties of that employment outside Canada. ...

Accordingly, where a transaction is structured such that it will avoid the application of more specific anti-avoidance rules the general anti-avoidance rule may still be applicable if it may reasonably be considered that the transaction would result in a misuse or abuse of the provisions of the Act. ...

But the renounced expenses are considered to have been incurred by a shareholder corporation during its taxation year in which the year of the joint exploration corporation ends. ...

A forward sales contract transaction in respect of a resource company's own production is generally considered as a "non-speculative" transaction. ...

Advantages which remain in the plan (such as bonus interest earned on the plan's investments) are not considered to be granted to the annuitant, and therefore do not contravene the provision. ...

Will the trust's income received by the beneficiaries be considered to be the personal property of an Indian situate on a reserve for purposes of the exemption from taxation contained in the Indian Act? ...

There has been no change in our position as set out in the interpretation which reads, "It is our view that the portion of the fee as may reasonably be considered to relate to the cost of Player Rights will be deductible in computing the income of the partnership for purposes of section 9 of the Act. ...