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For example, a corporation whose objectives include the provision of accommodation to persons other than the aged would not be considered exclusively for the aged. ... A statement indicating whether, to the best of the Applicant's knowledge, the CRA has at any time considered the corporation's eligibility as a low-cost housing corporation within the meaning of paragraph 149(1)(i) of the Act. ...

For example, maintaining reasonable operating reserves or bank accounts required for ordinary operations will generally be considered to be an activity undertaken to meet the not-for-profit objectives of an organization. ... However, if a material part of the excess is accumulated each year and the balance of accumulated excess at any time is greater than the association's reasonable needs to carry on its non-profit activities (see ¶ 9), profit will be considered to be one of the purposes for which the association was operated. ...

In addition, you have enquired about whether logging trucks specifically designed for dirt or gravel roads would be considered "prescribed property" for purposes of section 8200 of the Income Tax Regulations (the "Regulations"). ... " If logging trucks in question are not considered "prescribed property" as defined in section 8200 of the Regulations, then a subsection 16.1(1) election may be contemplated provided other conditions of the provision are met. ...

In general, an entity will be considered to be operating a business in a normal commercial manner if it habitually engages in an activity that is capable of producing a profit. ... As a result, the Academy would not be considered a non-profit organization as defined in paragraph 149(1)(l) of the Act. ...

It is our view that union dues used to fund the pension plan of union employees are generally not considered levied for or under a superannuation fund or plan. ... It is also our view that union contributions to a pension plan for its employees are generally considered to be related to the ordinary operating expenses of the union. ...

Paragraph 3 of Interpretation Bulletin IT-95, Foreign Exchange Gains and Losses, provides that generally, where borrowed funds are used in the ordinary course of a taxpayer's business operations, any foreign exchange gain realized on the repayment of the loan is considered to be an income gain and any foreign exchange loss incurred on repayment of the loan is considered to be an income loss. ...

We understand that, to the best of your knowledge, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) before the courts, or if a judgment has been issued, the time limit for appeal to a higher court has not yet expired. (v) is the subject of a ruling previously considered by the Directorate in respect of the taxpayer or a related person. ...

The “licence fee” can be considered to have the following components: 1. ... Therefore, a payment for the right to distribute the custom computer software in Canada could be considered in respect of a copyright in respect of the production or reproduction of a literary work and be exempt from Part XIII tax pursuant to subparagraph 212(1)(d)(vi). ...

Reasons: The complex continuing care co-payment that is paid to a public hospital while the patient is receiving medical services is considered to be in respect of those medical services and may be claimed under paragraph 118.2(2)(a) of the Act as a medical expense. ... In our view, the complex continuing care co-payment paid to a public hospital, although identified as being for meals and accommodation while the patient is receiving medical services, can be considered to be in respect of medical services of the type offered at a hospital and therefore, would be eligible under paragraph 118.2(2)(a) of the Act as a medical expense. ...

16 June 2015 External T.I. 2014-0553331E5- Indian Business Income XXXXXXXXXX CRA Tags 81(1)(a) Indian Act 87(1)(b) Principal Issues: Whether business income earned by an Indian XXXXXXXXXX who provides XXXXXXXXXX services to First Nation individuals in XXXXXXXXXX facilities on-reserve and off-reserve is considered to be tax exempt pursuant to paragraph 81(1)(a) of the Income Tax Act and section 87 of the Indian Act? ... Therefore, it is our view that the income derived from the business activities carried out at XXXXXXXXXX off the reserve would not be considered to be situated on a reserve and therefore would not be exempt from tax under paragraph 81(1)(a) of the Act and section 87 of the Indian Act. ...