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Furthermore, horses used in a riding business would not be considered inventory of that business.  ... This means that although the original cost of acquiring the horses, as well as the cost of any expansion in the number of such animals, is considered a capital-expenditure, the cost of replacing these horses is considered a deductible expense in the year of replacement. ...

Our position is unchanged from that stated in the February 21, 1983 letter in which we opined that a corporation deriving its income primarily from the provision of services would not be considered a "principal business corporation" within the meaning of paragraph 66(15)(h) of the Act, notwithstanding that the services provided are in respect of activities described therein. ... The determination would be one of fact which must be considered by reference to the various activities in which the corporation is engaged.  All activities of the corporation throughout the relevant taxation year must be considered. ...

In addition, the "primary use" of the asset is considered relevant in distinguishing between an inventory item and capital property.  ... The Department has recognized that items, which are consumed in the income earning process or are technically obsolete due to changing customer requirements, would be considered inventory subject to valuation within the meaning of subsection 10(1) of the Act despite arguments that such items in some cases could be considered capital.  ...

Further, for a 149(1)(l) entity, expenditures incurred in renovating a building used in its day-to-day activities would not be considered to relate to the entity's income from property. ... In computing the taxable income of the deemed trust, interest income is typically considered to be income from property and included in the calculation of that taxable income. ... Then, based on hypothetical facts, CRA provided comments on what might be considered to be currently deductible by the taxpayer in the calculation of its business income and what could reasonably be considered to relate to the period of construction. ...

For the purpose of subsection 126(2), would the Canadian corporation be considered to carry on business in the US? ... For the purpose of the foreign tax credit stated in subsection 126(2), would the Canadian corporation be considered to carry on business in the US? ... If a vendor of machinery, for example, provides to customers an engineer to supervise the installation of the machinery, this service would generally be considered to be incidental to the activity of selling the machinery; however, this type of service could in some cases be considered to be a significant activity on its own, depending on the machinery being sold, the nature of the installation service, and the terms of the contract with the customer. ...

Brother may claim the above-mentioned credits if he is considered to be the parent of Sister. ... Paragraph 252(1)(b) of the Act provides another way by which Sister might be considered a child of Brother. ... From the facts, it would appear that Sister would not be considered Brother's child, pursuant to paragraph 252(1)(b) of the Act. ...

YOUR QUESTION You have asked us whether the reimbursement of the legal fees would be considered to be a reimbursement of "personal" expenses of the Employee and therefore are properly characterized as a taxable benefit or, alternatively, whether the reimbursement would be considered a reimbursement of expenses incurred by reason of employment and would not be characterized as a taxable benefit to the Employee. ... " In our view reimbursements of personal expenses by an employer are considered to be "benefits of any kind whatever" received by an employee by virtue of office or employment and therefore these amounts have to be included in income under paragraph 6(1)(a). ... Whether specific legal fees reimbursed by an employer would be considered to be an employee's personal expenses is a question of fact that can only be determined after a complete review of the circumstances in each case. ...

Since only "rent" is used in paragraph 212(13)(a), the annual payments for updates, etc. would not be considered to be rent for purposes of that paragraph. ... In the situation at hand, the question is whether the annual payments paid by XXXXXXXXXX as described above would be considered to be "rent for the use in Canada of property" referred to in paragraph 212(13)(a) of the Act. ... Royalties, which are akin to rental payments, have invariably been considered as income since they are either based on the degree of use of the right or on the duration of the use, while a lump sum payment for the absolute transfer of a right, without regard to the use to be made of it, is of its nature considered a capital payment, although it may of course be taxable as income in the hands of the recipient if it is part of that taxpayer's regular business. ...

You referred us to a previous opinion letter identified as E51734 and queried whether XXXXXXXXXX acquisition of the right to sell franchises would be considered to constitute "originating property". ... As noted in paragraph 2 of Interpretation Bulletin IT-290 the word "principal" is considered synonymous with the words "chief" and "main", however for the purposes of paragraph 125(7)(e) it is the principal purpose of the business which must be considered rather than the "principal business" as discussed in IT-290. ... The licence fees could pertain to the corporation's research and manufacturing business and thereby be considered to be earned as active business income. ...

Where separation is less than 90 days couple would each be considered a spouse of the other. 2. Where separation is at least 90 days the couple will have been considered separated prior to year end. 3. ... If they have satisfied these conditions then the common-law relationship will clearly be considered a spousal relationship as at the particular time. ...