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It is our view that as long as the connection between two things or actions is easily discernible then the two things or actions could reasonably be considered to be related. ...

Even though the legislation (i.e. paragraph 149(1)(l) of the Act) would appear to be quite clear in that an NPO cannot have, as one of its purposes, the making of profit, jurisprudence with respect to paragraph 149(1)(l) of the Act has taken a somewhat more liberal interpretation and, generally speaking, has considered income earning activities of an NPO acceptable as long as the activities do not indicate that such profit was other than subordinate to achieving their exempt objectives. ...

It is our understanding that where payments under a particular program are considered as FSP, a T-slip will be required to be issued unless the total amount paid to the recipient in the year in respect of that program is less than $100. ...

Please note that we have not considered the impact of the transactions in paragraph 5 since there is no evidence that this is a common situation or one that could have an impact on a number of taxpayers. ...

Principal Issues: 1) Whether amounts received by a taxpayer in a particular situation should be included in its income by virtue of paragraph 12(1)(a) of the Act and whether such taxpayer may claim a reserve for a reasonable amount pursuant to paragraph 20(1)(m) of the Act. 2) Whether such amounts would be considered active business income for purposes of the Act. ...

All of the relevant facts must be considered in concluding whether a specific scenario come within the ambit of subsection 105(1) of the Act. ...

Based on CCRA's administrative position, subsections 40(3.3) and 40(3.4) would be considered to apply to deem a portion only of the transferor's loss to be nil in the second given fact situation. ...

In such a case, the impact of subsection 248(3) should be considered. ...

Robert Read, représentant alors Revenu Canada, à la conférence annuelle de 1988 de l'Association canadienne d'études fiscales: If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. (1988 Conference Report, page 18:6) Selon vous, les commentaires de M. ...

Reasons: In the particular situations, an arm's length purchaser should not be considered to be a "legal representative" as those terms are defined in subsection 248(1) of the Act. 2001-011260 XXXXXXXXXX S. ...