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Furthermore, where a future income tax asset becomes a tax receivable, this tax must be considered as an asset in determining whether a share is a QSBCS or if a corporation is an SBC. ...

. … However, when a future income tax asset becomes a tax receivable, such tax receivable must be considered as an asset for determining if a share is a QSBCS or a corporation is a SBC. ...

. … Income that is not incidental will usually be considered to be income of the unit owners, if this is appropriate under the relevant provincial law. ...

. … Income that is not incidental will usually be considered to be income of the unit owners, if this is appropriate under the relevant provincial law. ...

As such, the PLOI election in respect of the New Loan cannot be made or, if it was made, it would be considered invalid with the result that no interest income under subsection 17.1(1) would be imputed to the Canadian lender in respect of the New Loan. ...

CRA noted that as "the concept of residence necessarily implies that the person must be in existence," a (deceased) Canadian testator could not be considered to be a "resident contributor" in respect of the trust. ...

CRA responded: [A] person is considered to be living separate and apart from an individual… if the person lives separate and apart from the individual at that time because of a breakdown in their marriage or common-law relationship for a period of at least 90 days that includes that time. ...

Its fermentation tanks and barrels were considered to likely qualify for class 29 purposes as property used primarily in the manufacturing or processing of goods for sale. ...

Its fermentation tanks and barrels were considered to likely qualify for class 29 purposes as property used primarily in the manufacturing or processing of goods for sale. ...

Should the subsidiary be considered to have agreed to issue or sell the shares for purposes of s. 7, and would s. 7(3)(v) preclude a deduction by the subsidiary. ...