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For this reason, we believe that it would be more appropriate to consider this matter in the context of an advance income tax ruling request wherein all of the facts of a particular situation can be considered. ...

In our view, contributions to candidates in municipal elections are considered to be gifts.  ...

It has been our position that any amounts determined under the aforesaid subparagraph will be considered to have been incurred by the partner on the last day of the partnership's fiscal period.  ...

"The following changes in respect of the debt obligation itself(unless carried out pursuant to an authorizing provision in its original terms) are considered to be so fundamental to the holder's economic interest in the property that they almost invariably precipitate a disposition: (a) a change from interest-bearing to interest-free or vice-versa, (b) a change in repayment schedule or maturity date,... ...

At the 1984 Canadian Tax Foundation conference, it was stated that, generally speaking, a debt obligation is considered to arise whenever a binding liability is created and the principal amount of the liability can be quantified.  ...

Furthermore, plans which permit the rollover of unused credits to be applied to other plans under the flexible benefit plan are not considered to be a PHSP. 2.      ...

We considered the situation where a resident multinational life insurer in the course of carrying on its insurance business acquires large amounts of various bonds. ...

The reduction determined under subsection 39(9) is considered a capital loss which the taxpayer may deal with as permitted under the Act.  ...

(b)     1984 Conference Report: Q.62      "Factors which have been considered in establishing whether particular shares were or were not acquired in the ordinary course of business are at follows;      1)   the nature of the holder's activities,      2)   the number and frequency of such share acquisitions by the holder,      3)   whether the funds involved represent the initial capitalization of a new subsidiary or the provision of additional operating capital to a subsidiary both of which would indicate permanent capitalization,      4)  ...      5)  ... ...

Paragraph 5 offers some specific examples of business operations that are considered to be of the same kind.  ...