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In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001 issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...

Can land and timber be considered "qualified farm property" under subsection 110.6(1) of the Act? ... Can the land and timber be considered a capital asset in a "forest planting" situation? ... The sale of timber is considered income from the business of farming. ...

Whether more than one meal allowance may be provided during a period of overtime without being considered a taxable benefit. ... Less than three times a week will generally be considered infrequent or occasional. ... Therefore, the first meal allowance received by an employee would be considered a taxable benefit since it was received after one hour of overtime. ...

The situation you describe involves the accumulation of funds for a new business and whether those funds would be considered to be used in an active business. ... Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize the business. ... Cash balances which accumulate and are then depleted in accordance with the annual seasonal fluctuations of an ongoing business will generally be considered to be used in the business, but a permanent balance in excess of the company's reasonable working capital needs will generally not be considered to be so used. ...

Principal Issues: 1) is the purchase of a unit of a partnership involved in an active business considered investment of funds for 132(6)(b)(i)? ... Issue #5 Is the writing of covered call options by a Fund considered to be investing of its funds for the purpose of subparagraph 132(6)(b)(i) of the Act? ... In general, such transactions are considered ancillary to investing or part of a wide range of investing activities. ...

Principal Issues: Whether business of a corporation is considered a specified investment business for the purposes of ss. 125(7) of the Act. ... Interpretation Bulletin IT-479R lists some of the factors to be considered in making such a determination. ... You also ask how many employees in the situation described above would be considered employed on a full-time basis in the investment business. ...

Accordingly, the ordinary definition of farming is somewhat fluid and the particular activities undertaken by a taxpayer would have to be considered on a case-by-case basis. ... " Notwithstanding the above, where a taxpayer's activities primarily involve the cultivation, raising, or breeding of animals (husbandry) for use as a food source (even from non-traditional food or novel sources), such activities would generally be considered as farming, even though the animals would not be considered as livestock. ... However, the raising or breeding of rodents or other animals to be sold for use as pets would not be considered as farming. ...

Based on this definition, the right to purchase an apartment should be considered an option for purposes of the Act. ... Therefore, the right to purchase in the present case should be considered an option in respect of the apartment unit. ... Based on above, the right to purchase the apartment unit would be considered a taxable Canadian property. ...

Reasons: Costs to make instructor available at overseas site are considered integral to the course and therefore a basic cost of instruction. ... In your email, you have concluded that most of the Program Fee would likely not be considered eligible tuition fees. ... Generally, these fees are considered eligible fees as they relate to the process of instruction whereas the fees described in paragraph 27 of IT-516R2 relate to fees paid for some other goods or services provided by the educational institution and are therefore, not considered eligible tuition fees for purposes of the Tuition Tax Credit under section 118.5. ...

23 June 2005 External T.I. 2005-0127911E5- residence of a trust Unedited CRA Tags 104 Principal Issues: Will Canada recognize a trust as a resident of the US if it is considered resident in the US for US tax purposes? ... copies of the Canadian and U.S. income tax returns filed by the Trust for the period in which the Trust is considered resident in both countries;? ... However, irrespective of whether the Trust is considered resident in Canada or the U.S. for the purposes of the Canada-U.S. ...