Search - considered

Since each separate organization operates independently and would be considered a person as defined in subsection 248(1) of the Act each of the XXXXXXXXXX organizations would be considered a separate employer. ... Therefore, the XXXXXXXXXX organizations would not be considered to be associated employers. To summarize, it is our view that for purposes of section 126.1 of the Act the XXXXXXXXXX organizations would be considered separate employers who are not considered to be associated employers. ...

In our view, it is entirely a question of fact whether the cultivation of fish can be considered to be "farming for the purposes of the definition in subsection 248(1) of the Act. ... When determining whether business operations are of the same kind, the principal factor to be considered is the type of business the taxpayer is in.  See Interpretation Bulletin IT-206R for a fuller discussion of these and other factors to be considered.  ...

and (ii) Would time spent educating teachers and daycare providers be considered time spent administering therapy? ... Generally, teachers or daycare providers would not be considered to be primary caregivers. ... What would be considered essential to one person’s impairment may not be considered essential to another. ...

Would an amount included in income pursuant to subsection 94.1(1) of the Act be considered "aggregate investment income" as defined in subsection 129(4) of the Act? ... An amount included in income pursuant to subsection 94.1(1) would be considered to be from a source that is a property. ... An amount included in income pursuant to subsection 17(1) would be considered to be from a source that is a property. ...

Primary purpose of trip must be considered for work related stop on way home or to regular workplace. ... In our view, travel from home to a company facility is considered personal. However, travel between various facilities would probably be considered employment related. ...

For United States tax purposes, CanLP will be considered to have disposed of the shares of Canco. ... USCo is considered to earn interest from the loan and USCo and USSub are considered to have incurred a proportionate share of the interest expense payable by ULC on the loan from USCo. ... Had ULC not been considered a disregarded entity, USCo would be considered to have made an interest-bearing loan to ULC. ...

Assuming that Country X is Canada and the merger takes place as described in paragraph 2 above, (i)     Shareholder B will be considered to have alienated his shares of BCo at their tax cost  and to have acquired the shares of ACo at that cost, (ii)     alternatively, Shareholder B and ACo may Jointly elect at a higher amount (but not exceeding the fair market value of the shares of BCo) and Shareholder B will be considered to have alienated his shares of BCo at such elected amount and to have acquired the shares of ACo at that amount, (iii)     on the liquidation of BCo, BCo will be considered to have alienated all of its property at its fair market value and ACo will be considered to have acquired such property at that fair market value. 8.      ... The tax consequences under the Act to ACo and BCo of such a merger are not clear and ACo and BCo may be considered to have alienated any property that becomes a property of ABCo as a result of the merger at the fair market value of such property and  ABCo may be considered to be a new corporation that acquired such property at a tax cost equal to the fair market value thereof.  ... Assuming that Country y is Canada and that the results of the merger are as described in paragraph 5-above, (i)     Shareholder B will be considered to have alienated his shares of BCo for an amount equal- to the fair market value of the shares of ABCo received by Shareholder B by virtue of the merger, (ii)     BCo will be considered CO have alienated all of its property at its fair market value and ABCo will be considered to have acquired such property at that fair market value, and (iii)     any income or gain realized by BCo on such alienation of property will be subject to tax-in Canada. 10.      ...

The harvesting of peat and the manufacturing and processing of compost, by themselves, are not generally considered to be farming activities. ... However, this list is not considered exhaustive. The Farming Income Guide- T4003 published by the CRA lists other activities that may be considered farming, such as tree farming, cultivating crops in water or hydroponics, Christmas tree growing, operating a wild game reserve, operating a chicken hatchery, operating a feedlot. ... In and of itself, simply buying worms for resale and/or picking and packing worms for shipment would not generally be considered farming activity. ...

Reasons: A mineral right is generally considered an intangible property. ... Finally, we opined that a mineral right of a reporting entity would be considered a tangible property and therefore, a specified foreign property pursuant to paragraph (b) of that defined term in subsection 233.3(1) of the Act. ... In addition, we wish to clarify that a mineral right would likely be considered an intangible property. ...

Our Comments Subsection 252(4) of the Act is used to determine whether a couple living together in a common-law relationship are considered as spouses in respect of each other and when that spousal relationship is considered to begin or end. ... At any particular time prior to these two criteria being met both the individual and the taxpayer would be considered unmarried (or single) with respect to that relationship. ... Consequently, to specifically answer your questions; in the first situation, the marital status of the couple will not be considered to have changed until the date of birth of their child in common, and in the second situation, the marital status of the couple will not be considered to have changed until June 1, 1993. ...