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However, by virtue of the "available for use rules" found in subsections 13(26) to (31) of the Act, CCA for a Class 43.1 or Class 43.2 property that has been acquired and which is not considered available for use at the end of a taxation year may be restricted until such time as the property is available for use. ...

For purposes of interpreting the Canada-XXXXXXXXXX Convention, the better view is to consider that the two Canadian partnerships are not separate persons with respect to the partners and the immovable property held by the intermediary of such partnerships should be considered as included in Canco's assets, according to its percentage of partnership interest. ...

Section 142.5 of the Act generally requires a taxpayer that is a financial institution to annually include in computing income the increase or decrease in value of securities that are considered mark-to-market property. ...

Since the decree indicates an appointment for XXXXXXXXXX, the duties performed are not considered of a temporary nature, the allowance does not meet the conditions under subsection 6(6). ...

Only if the correction of the errors would make the year taxable, so that an assessment is required, must the statute bar be considered. ...

An additional situation where the penalty each spouse is liable to under paragraphs 163(2)(c) and (c.1) may be calculated based on the entire amount of the benefit overpayment may occur when each spouse’s understatement of income is such that, when considered on its own, it is directly attributable to the full amount of the benefit overpayment. ...

The issue was, of course, whether the profit would still be considered to be a capital gain in the light of the short holding period of the recipient corporation. ...

However the reassessment can only be made to the extent that the reassessment can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. ...

The term "debt obligation" is considered to include, for example, bank accounts, term deposits, guaranteed investment certificates, Canada Savings Bonds, mortgages, corporate bonds and loans. ...

An improvement that is a renovation or alteration of a residence or of the land on which the residence is situated, or that is part of the construction of the residence that can reasonably be considered to be undertaken o to enable a senior to gain access to, or to be mobile or functional within, the residence or the land, or o to reduce the risk of harm to a senior within the residence or the land or in gaining access to the residence or land. ...