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The transactions described in the particular situation, in and by themselves, would generally not be considered to result in any disposition or increase in interest to an unrelated person as described in subparagraphs 55(3)(a)(i) to (v). 2002-012588 XXXXXXXXXX S. ...

Paragraph 19 of Interpretation Bulletin IT-141R (Consolidated) (the "Bulletin") states that teaching is not considered administrative service, whether or not it is at a denominational school, college or seminary. ...

In respect of interest deductibility, it is the current use made of the borrowed funds in a particular year rather than the initial use of the funds that must be considered in determining whether the interest paid or payable with respect to the borrowed funds is deductible in a particular year. ...

Reasons: 1) In the two given fact situations, the lawyer should not be considered to be a "legal representative" of the seller as those terms are defined in subsection 248(1) of the Act. 2) Considering that the provisions of the Civil Code of Québec with respect to the sale of an enterprise have been repealed as of June 13, 2002, we consider that it is not necessary or pertinent to address this issue. 2002-013067 XXXXXXXXXX S. ...

For the purposes of the Act, following Swedish corporate law FA2 is considered to exist and be the payer of the interest payments to FA1 until the time of the merger. ...

., rents from the leasing of the boats), rather than the provision of a service, A Co would be considered to be carrying on an "investment business" and not an active business unless it meets the conditions of the exclusion to the definition of "investment business" described above; and (d) The lease payments payable by A Co. to B Co. must be deductible by A Co. in computing amounts prescribed to be its earnings or loss from its active business carried on outside Canada. ...

Question 4 The Federal Court of Appeal set out circumstances in which a person or group of persons would be considered to have de facto control. ...

It is a question of fact as to whether the children would be considered to meet the excluded business test with consideration given to the nature, and the labour requirements of Investco’s business. ...

In cases where proposed paragraph 248(1)(g) "disposition" definition does not apply (for example, where only a partial transfer of properties occurs between trusts of the same annuitant) the transfer may be considered to be a "qualifying disposition" pursuant to proposed subsections 107.4(1),(2) and (3). ...

However, we have not considered this issue in detail, as we do not have enough information to do so. ...