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Normally, a transaction is considered to be bona fide when its terms and conditions are essentially the same as they would be if the transaction were entered into by parties dealing at arm's length. ...

The CRA accepts that where an amount is paid by an employer in respect to an item that is primarily for the benefit of the employer or office (hereinafter referred to as "employer"), then it is generally not considered to be a taxable benefit to an employee or officer (hereinafter referred to as "employee"). ...

It is our opinion that the additional 20% of salary and wages that the employee received from the employer during the Sabbatical Year, over and above the deferred salary amount, would be considered to be additional salary or wages from the employer during the leave of absence. ...

Such income is considered salary, wages or other remuneration subject to withholding at source under subsection 153(1) of the Act. ...

A director could be considered to be about to become liable for the purposes of subsection 164(2) when the amount of the liability has been ascertained, all the required legislative pre-requisites have been complied with, and all that remains is for the assessment to be issued. ...

Answer to Question No. 3 An estate is considered fully administered, when the assets of the estate have been distributed and a clearance certificate is requested pursuant to section 116 or 159 of the Act. ...

Our Comments To determine whether there is a capital loss under subsection 39(2) of the Act, a number of issues need to be considered: 1. ...

" In Melo Pereira v The Queen, 2008 DTC 2924, Bedard J. makes the following comments when analysing who is considered a 'regular minister': "This Court has reviewed the meaning of the term "regular minister" several times. ...

Comments As you know, subparagraphs 8502(i)(iv) to (vi) provide an exception so as to permit an RPP to borrow money “for the purpose of acquiring real property that may reasonably be considered to be acquired for the purpose of producing income from property”, provided that the amount borrowed (and other debt) does not exceed the cost of the property acquired and that none of the plan’s property besides the real property is given as security for the borrowed money. ...

A corporation is considered to be a qualifying corporation if, among other things, it has, with respect to a qualified expenditure made by the corporation in the year, filed a prescribed form under section 127 of the Income Tax Act (Canada) (ITA). ...