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If the Canadian trucking company has to pay tax on its subsidiary capital allocated within the State of New York, only that portion of the New York State franchise tax computed using the method described in (a)(i) or (a)(iii) above is considered to be an income or profits tax for the purposes of section 126 of the Act. New York State franchise tax computed using methods other than those described in this paragraph is not considered to be an income or profits tax because such tax is not based on income or profits but rather on capital invested or payroll expenditure. ... In our opinion, if the excise tax is computed on the basis of (a) described above, only that portion of the tax which is computed under (a)(ii) is considered to be an income or profits tax and is eligible for the foreign tax credit for the purposes of the Act. ...

If Canco is required to make a payment with respect to its guarantee of the loans of USco, Canco is considered in law to have acquired a debt owed by USco. ...

" The term "public body" is not defined in the Act and must, therefore, be considered to have the meaning assigned to it by dictionaries and common usage. ...

While a truck rental company would not be seen as having converted capital property to inventory where the leased trucks are being replaced only when worn out or obsolete [see Anthes Equipment Ltd. 87 DTC 59], where leased vehicles are withdrawn from leasing prior to that time and are sold as an integral part of the taxpayer's normal business operations, a conversion of the trucks to inventory is considered to occur prior to their sale [see Wang Canada Ltd. 91 DTC 1279; Canadian Kodak Sales Ltd. 54 DTC 1194]. ...

Consequently, since the Post-bankruptcy Period is a component of the calendar year in which the taxpayer became a bankrupt, and since an income tax refund is considered to be property under the BIA vesting in the trustee, it follows that a refund that arises from the filing of the post-bankruptcy return should form part of the bankruptcy estate. ...

In other words, any person paying WLRP benefits would be considered the employer and is required to withhold income tax from those payments. ...

Based on the facts provided, we considered the application of subsection 56(2) of the Act in respect of Forco, the Partnership's members, and XXXXXXXXXX (USco). ...

"Post-secondary school level" is considered a qualifying educational program where it includes a program of courses at an educational institution certified by HRSDC where the courses are of a technical or vocational nature designed to furnish a person with skills for, or improve a person's skills in, an occupation. ...

This reassessment has to be reasonably considered to relate to the change in the particular balance of the taxpayer for a particular year. ...

/ Whether the House of Commons can be considered a public body performing a function of government pursuant to 149.1(1)? ...