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This paragraph provides an exception to our general view that property which a taxpayer both sells and leases will be considered inventory unless certain requirements are met, including the operation of a separate leasing division. ... Obviously, if there is an option to purchase, the exception in paragraph 6 does not apply, and the particular farm equipment should be considered inventory. ...

When the settlor or other contributor is one of two or more co-trustees acting in a fiduciary capacity in administering the trust property and there are no specific terms outlining how the trust property is to be dealt with, but rather the property is subject to standard terms ordinarily found in trust indentures, we accept that paragraph 75(2)(b) will generally not be considered applicable. ... However, where the settlor or other contributor is one of two or more co-trustees acting in a fiduciary capacity in administering the trust property and there are no specific terms outlining how the trust property is to be dealt with, but rather the property is subject to standard terms ordinarily found in trust indentures, we accept that paragraph 75(2)(b) is generally not considered applicable. ...

If the assets held by your RRSP are paid to your wife as a consequence of your death before the RRSP matures, the payment will be considered to be a "refund of premiums" pursuant to the definition contained in subsection 146(1) of the Act and a deduction against the income inclusion discussed above will be allowed on your final income tax return pursuant to subsection 146(8.9) of the Act. ... Since the Canada-Mexico Income Tax Convention ("Convention") does not have a definition of "pension", payments out of a Canadian RRSP will be considered "pension payments" for purposes of the Convention pursuant to the Income Tax Conventions Interpretations Act. ...

In addition, a "housing unit" within the definition of "principal residence" is only considered to include one apartment in respect of an apartment building. ... Accordingly, based on the information set out above, it follows that none of the five rental units in respect of the Property may be considered the Owner's principal residence for any year. ...

The Supreme Court of Canada considered the approach to use in determining whether income is situated on a reserve and concluded that the proper approach in determining the situs of personal property is to evaluate the various connecting factors that tie the property to one location or another. ... For your information, crown land is generally not considered to be a reserve for purposes of the Indian Act. ...

Where the capital property has not been acquired for the purpose of gaining or producing income, the taxpayer would not be entitled to a deduction under paragraph 20(1)(a) and consequently the property would not be considered depreciable property for purposes of the Act. Whether a capital property is acquired for the purpose of gaining or producing income is a question of fact to be determined on a case-by-case basis, however, in the situation you describe, where the residence has been unoccupied since acquisition and has not been rented or otherwise used to earn income, in our view the property would not have been acquired for the purpose of gaining or producing income and consequently would be considered a non-depreciable capital property to the estate. ...

Interpretation Bulletin IT-65 dated September 8, 1972 states: "Where all the shares of a class of stock of a corporation are replaced by a greater or lesser number of shares of the same class of stock of the same corporation in the same proportion for all shareholders, in circumstances where there is no change in the total capital represented by the issue, there is no change in the interest, rights or privileges of the shareholders and there are no concurrent changes in the capital structure of the corporation or the rights and privileges of other shareholders, no disposition or acquisition is considered to have occurred. ... For example, if the taxpayer owned shares of X Corporation which he acquired before 1972 at a cost of $25 each and the value on valuation day was $40 each, then subsequently these were split 5 for 1, each new share will be considered to have a cost of $5 and a V-Day value of $8. ...

XXXXXXXXXX Wayne Antle, CGA 2002-014670 September 13, 2002 Dear XXXXXXXXXX: Re: Reimbursement of Tuition Fees This is in response to your letter of June 10, 2002, concerning whether the reimbursement of tuition fees by the XXXXXXXXXX (the "employer") for its newly-hired recruits would be considered a taxable employment benefit to the employees. ... Where specific training is taken by an employee in order to maintain or upgrade the employee's job-related skills, and it is reasonable to conclude that the employee will remain with the employer for a reasonable period of time after completing the course, then the training will generally be considered to primarily benefit the employer. ...

REASON FOR POSITION TAKEN: The terms of the settlement are considered to be consistent with CCRA's position set out in IT-365R2. ... To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier tax return of the Claimant or a related person; (ii) being considered by a tax services office or taxation center in connection with a previously filed return of the Claimant or a related person; (iii) under objection by the Claimant 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 expired; or (v) subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

Other jobs are considered local and do not provide any form of reimbursement. ... In that regard, expenses for travel between an employee's personal residence and the employer's place of business where the employee ordinarily reports are not deductible as these are considered personal expenses. ...