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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. ...

They considered the rental operation a business and deducted the losses, accordingly. ...

Paragraph 6 of IT-292, however, allows an amount to be considered an allowance when a deeming provision exists in the provincial Municipal Act, even though the local by-laws may require another allocation of salary. ...

Consequently, this travel is not considered as traveling « in the performance of the duties of the office or employment ». ...

(footnote 7) Based on these judicial tests, it is probable that the production of biofuels and chemicals from municipal solid non-recyclable waste and non-compostable residue may generally be considered as manufacturing or processing. ...

For example, in order for a child to be considered wholly dependent for support on a parent, the parent must be responsible for the usual day-to-day activities of raising the child, such as ensuring the child attends school, and providing necessities such as food, shelter and clothing.” ...

For clarity, the cost of an industrial mineral mine property is considered a capital cost, and not a Canadian development expense. ...

Reasons: Based on the textual, contextual and purposive interpretation of the relevant legislative provisions, on the facts at issue, the "amount deductible...under subsection 126(1) of the Federal Act" in element B of subsection 34(2) of the TAO in respect of each foreign country should be considered to be a proportionate share of the FTOP. ...

(b)     Drillco may be considered a financing vehicle for Oilco in the sense that it is not commercially viable for Oilco to issue its own flow-through shares to the public given the disparity between Oilco's own net asset values and the trading price of its shares. ...