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In conclusion, the five documents that we reviewed should be considered to be leases under Quebec law for the purposes of Part I and I.3 of the Act. ...

This view is consistent with the comments made by the Court on page 1753 in Oligny that: "the conditions that appear essential for an organization to be considered as a religious order are, in my view, first that the members adhere to the particular rules uniting them in a formal way and that those particular rules governing them be more compelling than those that consist simply in ratifying the beliefs established by the religion or the denomination to which they already belong. ...

In this regard, we note that, in Blanchet v. the Queen, (1996 D.T.C. 3209), in which the issue was the appropriate proportion of expenses considered to be personal in a shared accommodation situation, the court held that there was no reasonable expectation of profit but was precluded from further decreasing the taxpayer’s loss (and increasing tax payable) as a result of the appeal process. ...

Social Security Agreement (the “Agreement”) states that “where but for this Article, a person would be covered under the laws of both Contracting States in respect of earnings from self-employment, that person shall, in respect, thereof, be subject only to the laws of Canada if that person is considered to be resident in Canada for the purposes of the relevant provisions of those laws, and only to the United States laws in any other case”. ...

If the facility only acts as an agent for the residents for the retention of the services of the subcontractor, it will not be considered as providing the full-time care required under the Act. ...

" In this case, if on the particular facts, the legal fees are expenses incurred to defend against a prosecution which arose directly from owning and operating the gas service station, the legal fees could be considered to be incurred for the purpose of gaining or producing income from a business. ...

Since XXXXXXXXXX cannot be considered to be “engaged exclusively in full-time administrative service,” the remaining issue to be reviewed is whether or not he is “in charge of or ministering to a diocese, parish or congregation.” ...

The house would therefore be considered, for purposes of subsection 18(12) of the Act, a “self contained domestic establishment in which the individuals reside.” ...

We believe that support for the argument that management activities are considered to constitute the carrying on of business can also be found in the structure and wording of OECD-based income tax treaties such as those entered into by Canada including the Canada-U.S. ...

$XXXXXXXXXX which would not be considered by IRS as foreign death tax paid. ...