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Factors to be considered in making a determination include the purchase agreement, registration, taxpayer representations and identification of the person(s) who paid for the property. ...

The Agreement also provided that, should the Taxpayer be unable or unwilling to fulfil his return of service obligations, he would be required to pay back the full amount received under the Agreement, and it also provided that the financial support would be considered employment income. ...

Therefore, with respect to your inquiry, the specific lake on which a particular individual earned business income from fishing would have to be identified, and confirmation obtained from INAC as to whether that lake is considered to be part of a reserve, whether pursuant to the XXXXXXXXXX or otherwise. ...

The Queen (2001 DTC 496), the Tax Court considered whether subsection 127(5) of the Act imposed an ordering provision on claims for ITC. ...

We may "look-through" an arrangement where the trust may reasonably be considered to act as an agent for the beneficiaries. ...

Position: No Reasons: The payment represents a voluntary personal gift to the individual as a result of his status as a union member and would therefore is not considered a payment to "compensate for the loss of employment" as contemplated by subparagraph 56(1)(a)(ii) of the Act. ...

Please note that we have not considered the effect of other potential rights of setoff or rights of combination on the qualification of an account as a TFSA. ...

The consequences to a trust and a child entering into such a transaction would best be considered after the ability to under take the transaction is determined by the trustee. ...

Subsection 245(4) of the Act provides that subsection (2) does not apply to a transaction where it may reasonably be considered that the transaction would not result directly or indirectly in a misuse of the provisions of the Act or abuse having regard to the provisions of the Act, other than this section, read as a whole. ...

However, an essential prerequisite for an organization to be considered a religious order is the existence of vows or a specific religious discipline which sets it apart from other organizations within the religious denomination with which it is affiliated. ...