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With a view to being thorough, we considered if there is any recourse under the Act for USP to otherwise be considered to have filed the election. Could the election be considered effectively filed based on the taxpayer’s filing position? ... In that case, the election being considered is one available under subsection 39(4). ...

Would the Surplus Amount be considered Class 14.1 property if paid after the repeal of the ECP rules? ... The deduction of a reserve under paragraph 18(1)(e) was considered in Industries Perron Inc. v. ... Issue 2: Would the Surplus Amount be considered Class 14.1 property if paid after the repeal of the ECP rules? ...

Rulings on Formula-Based Appreciation Plans will no Longer be Considered (footnote 2) ITRD will no longer consider any ruling requests pertaining to whether any given formula-based appreciation plan is a SDA, unless: i) the plan is of a type described in ATR-45 – “Share Appreciation Rights Plan” (discussed later in this memorandum); or ii) the ruling request pertains to whether one of the enumerated exceptions listed in the definition of SDA apply to the plan. ... It also includes a “purpose” test that would be satisfied if it can be reasonably considered that one of the main purposes for the existence or creation of the right to receive a deferred amount under the plan or arrangement is tax deferral in respect of salary or wages attributable to past services. ... The CRA's longstanding position remains that a unit issued under a SAR plan with the above characteristics will generally not be considered to be a SDA. ...

Position: 1- No. 2- No. 3- It will depend on the plan under review. 4- Dealt verbally. 5- Not considered. 6- Yes. ... QUESTIONS 2 & 3: CAN THE ARRANGEMENT UNDER REVIEW BE CONSIDERED AS AN EMPLOYEE BENEFIT PLAN? ... In light of the answers given above, we have not considered the application of section 245 of the Act. ...

No, any capital gain realized on a subsequent disposition of the shares of the purchaser could not reasonably be considered to be attributable to the Intangible Property Safe Income for purposes of subsection 55(2) of the Act. ... Second Issue V.2 Reasonably be considered to be attributable to anything other than income earned or realized 33. ... The issue, therefore, becomes whether, in interpreting the phrase "reasonably be considered to be attributable" in subsection 55(2), the gains that accrued on FA's US Holdco shares in the Post-acquisition period and, therefore, the gains that accrued on PrivateCo's XXXXXXXXXX Canco common shares immediately before their redemption on XXXXXXXXXX, could reasonably be considered to be attributable to the Intangible Property Safe Income or to something else. ...

To determine if it is considered a municipality, a First Nation should contact the Agency's local tax services office. ... For a First Nation that is a municipality, the geographical boundary is considered to be the boundary of its reserve. ... However, if Corporation C only owns 95% of Corporation D, Corporation D is not considered exempt. ...

All subsequent year non-capital losses that have previously been deducted under paragraph 111(1)(a) should be considered. ... Where this occurs under either instalment method, that particular method will not be considered. ... Should previously applied non-capital losses from subsequent years be considered in recalculating CAD Taxes Payable resulting from a subsequent deduction for an additional non-capital loss? ...

Tax consequences (a) The amount of financial assistance relating to the destruction or total loss of such buildings will be considered the proceeds of disposition for the land and the building. ... Financial Assistance for damage (not considered a total loss) incurred by the owner of a residence. certain rental buildings and business properties Assistance- The owner could receive 100% of the value of the damage to the building, up to $100,000, plus 75% of the amount exceeding $100,000, but not more than 100% of the standard municipal assessment of the building alone, if the owner has suffered damage to the property mentioned in the preceding section, but not a total loss.- For essential business property or property required for the continuation of business operations, the Quebec government order 973-96 states that the damage to the land (except for cultivated agricultural land) and its landscaping, or to a woodlot, sugarbush or tree plantation are not eligible for financial assistance. ...

Are fax machines, printers, security systems or other machinery considered? ...

Where the property considered is a rental property held by a particular corporation, the property generally will be considered to be a business property where the income from the property can be considered active business income. On the other hand, where the income from the rental property can be considered to be income from property or income from a specified investment business, the rental property generally will be considered to be an investment property. Where the property considered is a share of a corporation held by a particular corporation, the share may be considered to represent any or all of the three different types of property depending upon the circumstances. ...