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However, if, in the absence of the corporation, there would be no common law master-servant relationship and the individual who undertakes to perform the services would be viewed as a self-employed individual carrying on a business, the individual would not be considered to be an incorporated employee. ... You have also asked about the expenses that a company could deduct where the company supplied drivers, operators or labourers and how a company could diversify its business so it that it would not be considered to be carrying on a personal services business. ...

Since paragraph 104(13)(a) of the Act is considered in computing net income for income tax purposes, it follows that it will also be considered in determining a person's entitlement to the GIS. ...

Accordingly, in our view, in this situation it would appear that the Individual could, at most, be considered to use 50% of the property. ... Accordingly, in our view, in the above situation it would appear that the Individual could, at most, be considered to use 50% of the property. ...

You should note that a wage loss replacement plan (WLRP) is not considered to be an EBP according to the definition of EBP in subsection 248(1). Rather, a WLRP is considered a plan to which paragraph 6(1)(f) applies. ...

A child is still considered to have resided with the annuitant if, before the annuitant died, the child lived away from home for educational reasons. If the child's net income was more than the amount described above, the child will not be considered to be financially dependent on the annuitant at the time of death, unless the child can establish the contrary. ...

We considered whether paragraph 69(1)(c) of the Act would apply to deem the Canadian resource property to be acquired by the estate at its fair market value at the time of such acquisition. ... We also considered whether paragraph 69(1)(c) of the Act would apply to deem the Canadian resource property to be acquired by the taxpayer's heir (i.e., the capital beneficiary) at its fair market value at the time of such acquisition upon the distribution of the estate's assets to its capital beneficiary. ...

The courts considered two main factors to connect business income to a location on or off a reserve. ... The income you receive from writing on subjects related to your heritage, would not be considered purchased by Her Majesty or given under a treaty and, accordingly, section 90 of the Indian Act would not apply to deem your business income to be situated on reserve. ...

Reasons FOR POSITION TAKEN: The terms of the settlement are considered to be consistent with the Department's position set out in IT-365R2 (in particular paragraphs 3 and 5). ... To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is, in an earlier return of the taxpayer or a related person, 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 or is under objection by the taxpayer or a related person and is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

It states that each request is considered on its own merits, taking into consideration sound business reasons. ... As in the case of considering requests for fiscal year-end changes, the Circular states that each request will be considered on its own particular merits. ...

The definition of residency of the employer in the Guidelines would also need to be considered in relation to an individual's employer. ... The Guidelines provide the following explanation of central management and control: The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ...