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Generally, for a course to be considered to be at the “post-secondary level” the course should provide credit towards a degree, diploma or certificate and a prerequisite for taking the course should be completion of secondary school. ... For applicants who do not have the minimum admission requirements for a Diploma Program but who are at least 19 years of age by the first day of classes may be considered as mature students. ...

.: E 9729770), in reply to the question whether post-sales services performed by a U.S. subsidiary of a Canadian parent corporation on products purchased by customers directly from the Canadian parent would be considered "services performed in connection with... the sale" for the purposes of paragraph 95(3)(b), Canada Customs and Revenue Agency answered, in part, as follows: "Generally, however, it is our view that only services that are directly related to the sales function would qualify. ... And on that basis you submit that the […] services described herein should be considered services performed in connection with the sale of goods by Canco. ...

Paragraph (e) of the definition of TCP in subsection 248(1) describes the conditions under which the shares of a public company would be considered TCP: "a share of the capital stock of a corporation that is listed on a designated stock exchange...…, if, at any particular time during the 60-month period that ends at that time, (i) 25% or more of the issued shares of any class of the capital stock of the corporation, or 25% or more of the issued units of the trust, as the case may be, were owned by or belonged to one or any combination of (A) the taxpayer, and (B) persons with whom the taxpayer did not deal at arm's length, and (ii) more than 50% of the fair market value of the share or unit, as the case may be, was derived directly or indirectly from one or any combination of properties described under subparagraphs (d)(i) to (iv). ... Thus, for the purpose of determining whether the non-resident partner is taxable under subsection 2(3) of the Act, the partners of the partnership are considered to have disposed of their respective interest in the property of the partnership and paragraph 96(1)(c) does not apply (footnote 4). ...

Where a student is not considered to be enrolled as a full-time student, the student may be eligible for the part-time education tax credit if the program in which the student is enrolled meets the requirements of a specified educational program and the student spends not less than 12 hours per month on courses in the program. ... This paragraph states, in part: Generally, for a course to be considered to be at the post-secondary school level: a) the course should provide credit towards a degree, diploma, or certificate; and b) a prerequisite for taking the course should be completion of secondary school. ...

(footnote 1) Paragraphs 13(4)(a) and 44(1)(a) of the Act provide that in order for a particular disposition of former property to be considered as being involuntary, the POD must fall in one of paragraphs (b), (c) or (d) of the definition of POD in subsection 13(21) of the Act or section 54 of the Act, as the case may be. ... Accordingly, the Taxpayer needed to acquire property that was considered as a replacement property by XXXXXXXXXX. ...

It is considered a cost of doing business. 2-Subparagraph 18(1)(t)(ii) only provides a deduction for interest accrued in a taxation year that commenced before April 1, 2007. 3- In accordance with section 67.6 of the ITA, fines or penalties that have been imposed after March 22, 2004 are not deductible by a taxpayer. ... The ITC would be considered repaid in the year of reduction. Therefore, for the portion of the GST reassessment that relates to the reduction of ITCs claimed, the amount will be allowed as a deduction for income tax purposes, in the year the liability arises (i.e., the year of assessment), if these ITCs were previously included in income for income tax purposes. ...

De facto control: A corporation is considered by subsection 256(5.1) to be "controlled, directly or indirectly in any manner whatever," where another corporation, person or group of persons has any direct or indirect influence that, if exercised, would result in de facto control of the corporation. ... This would also be the case if we considered BCO's right contained in article XXXXXXXXXX of the Agreement and paragraph 251(5)b). ...

., be considered a member of a religious order, we have to determine if the Entity is a 'religious order'. ... Accordingly, the Taxpayer is not considered to be a member of a religious order. ...

The Taxpayer indicated in his notice of objection that he reasonably determined that he would not recover the debt as a whole, and considered the $XXXXXXXXXX debt to be bad in XXXXXXXXXX. ... As also stated in paragraph 3 of IT-220R2, a debt is considered bad for the purpose of section 20(4) only when the whole amount is uncollectible or when a portion of it has been settled and the remainder is uncollectible, not where the amount is merely a doubtful account. ...

Paragraph 2 of IT-365R2, Damages, Settlements and Similar Receipts, indicates that amounts received by a taxpayer as special or general damages for personal injury or death will generally be non-taxable; however, an amount which can reasonably be considered as income from employment rather than an award of damages will not be excluded from income. Generally, it is our view that an award of damages for "libel" (i.e. defamation of character, slander, etc.) would be considered for personal injury and would not be taxable, and as such legal fees incurred to obtain a non-taxable award would not be deductible. ...