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Hence the deceased is not considered in the determination of a "resident contributor". ... Accordingly, the Estate will be considered to be a contributor to the Trust. ... Therefore, in the given instance, the deceased is also considered to be a contributor to the Trust. ...

11 August 2015 External T.I. 2014-0527291E5 F- Remboursement de frais médicaux-CIMAD-- summary under Paragraph 118.2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(3)- Paragraph 118.2(3)(b) Quebec Tax Credit for Home-Support Services for Seniors does not reduce METC 2013-0490901I7 reversed 2001-0113237 in finding that the Ontario Healthy Homes Renovation Tax Credit would not be considered a "reimbursement" for purposes of s. 118.2(3)(b). What about the Québec refundable tax credits could be considered as a "reimbursement" of medical expenses for purposes of paragraph 118.2(3)(b), in particular, the Tax Credit for Home-Support Services for Seniors ("CIMAD"), the Independent Living Tax Credit for Seniors ("CIALB") and the Rehabilitation Centre Tax Credit ("CISUT") – and may an individual who has treated a CIMAD as a medical expense for such purposes amend their tax returns for the last 10 years to adjust the calculation of the Medical Expenses Tax Credit ("METC")? CRA stated: [T]he CIMAD, CIALB and CISUT would not generally be considered a "reimbursement" for purposes of paragraph 118.2(3)(b) in a situation where an expense that is eligible for any of these credits is also an eligible expense for the METC. ...

…In the event that, without being equivalent, the hourly rate of a volunteer firefighter is comparable to that of a regular firefighter, we are of the view that the amount paid would not be considered "minimal". As a result, the firefighter in this situation would not be considered to be acting as a volunteer for the purposes of subsection 81(4) and section 118.06. … [A]n individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06. ...

Management and control of an organization is generally considered to be exercised by the group that performs the functions of a board of directors of the organization. ... Where an organization, which would not otherwise be considered as resident on the reservation, claims that it meets the definition because it holds its board meetings on the reservation, it should generally be considered to meet the definition where the management and control of the organization is legitimately exercised during those meetings. ...

Should weekend days be considered in computing the automobile standby charges; and would travel between home and a place of work in response to an emergency call be considered personal or work-related? ... Thus, weekend days must be considered in calculating the taxable benefit under paragraph 6(1)(e) and subsection 6(2). … [U]se of a motor vehicle [is not] personal use if the employer requires the employee to travel directly from the employee’s home to a place other than the place of business where the employee regularly reports, or to return home from that place. … [T]he borough's public works office is a regular place of employment for the foremen. ...

Under the ITA, the LP would be deemed to be a non-resident person for Part XIII purposes and that fictional person would be related to Canco under s. 251(2), so that the interest would be considered to be ineligible for the domestic exemption for arm’s length interest. ... In this regard, CRA stated that it was in general agreement with a submission that referred to the statement in Folio S1-F5-C1 that “when a partner is not in a position to control a partnership…that…partner is dealing at arm's length with the partnership,” and reasoned that a partner who is considered to be dealing at arm’s length with a partnership should also be considered to be dealing at arm’s length with the corporation controlled by the partnership. ...

Before concluding that the Association would likely be considered a trade union, so that annual dues paid to maintain membership in the Association likely would be deductible, CRA stated that under its established position: [A]n association does not have to be certified trade union in order to be considered a trade union for purposes of subparagraph 8(1)(i)(iv)…. Generally, an association whose primary purpose is to collectively negotiate with an employer to further the working conditions of its members is considered to be a trade union for purposes of subparagraph 8(1)(i)(iv). ...

26 September 2018 External T.I. 2018-0770911E5- Revised income sprinkling rules-- summary under Paragraph 120.4(1.1)(a) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(a) parental leave need not detract from satisfying the regular, “continuous” and substantial TOSI test Would the correspondent’s spouse, who normally works, on average, more than 20 hours per week in the business of the correspondent’s corporation for the year, but who is currently on leave due to the birth or adoption of a child, still be considered to have been “actively engaged on a regular, continuous and substantial basis” in the activities of the business for that year? ... CRA stated: Based on the above, there are certain situations where the average work commitment could be considered as being “regular, continuous and substantial” even if the bright-line deeming rule is not met. Accordingly, the fact that an individual was unable to work for a portion of a year in which the business operated due solely to the adoption or birth of a child would not, in and by itself, mean that the individual was not otherwise considered to meet the regular, continuous and substantial requirement for that year. ...

B is, to a large extent, intended to compensate her for the care given to the child, the total amount will be considered to be remuneration for attendant care. However, if this is not the case, the global amount charged will be considered as an amount paid for the child's room and board (with all services included) and not as an amount paid to Ms. ... B charged a detailed amount for all the services provided, i.e. a specific amount for room and board and a specific amount for the care she provides to the child, the amount charged specifically for care would be considered as remuneration for the attendant care. ...

. … The amount of sales taxes paid by the charity need not be considered … nor should the amount of tips be considered. … [I]f the value of the free items given to all participants in the golf tournament, for each ticket sold, does not exceed the lesser of $75 and 10% of the ticket price, this amount will not be considered an advantage …. ...