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In this regard, we would be inclined to conclude that generally a parent's home cannot be considered a dwelling of the patient if the patient has his or her own rented apartment that the patient uses year-round. ...

A program is not considered a qualifying or specified educational program if the student receives, from a person with whom he or she deals at arm's length, a grant, reimbursement, benefit or allowance for that program, with certain limited exceptions. ...

Any portion of the land in excess of 1/2 hectare may also be considered part of the eligible dwelling if the individual establishes that the respective portion is necessary for the use and enjoyment of the housing unit. ...

In other words, could the Branch Advances be considered loans from a specified non-resident shareholder (ACO) to a person (the Branch)? ...

Question 2 In 65302 British Columbia Ltd [2000] 1 C.T.C.57, the Supreme Court of Canada held that fines and penalties incurred in the ordinary course of earning income were generally deductible in computing income from a business or property, unless the underlying action or omission was so egregious or repulsive that the fine or penalty could not reasonably be considered to have had an income earning purpose. ...

Our Comments We have carefully considered the taxpayer's representative's submission. ...

The will also provides that the executors were entitled to hold the property of the estate in trust for as long they considered necessary. 3. ...

Internal Revenue Service that a "similar privilege" would not be considered to be given to a Canadian officer or servant of the same class by the U.S. as referred to in subparagraph 149(1)(a)(ii) of the Act noted above. ...

Likewise, if the Trust is to be considered a non-resident for the purpose of computing the portion of its taxable income derived from the disposition of taxable Canadian property, you ask whether it would be appropriate to require the Trust to obtain a T2064 or T2068 Certificate of Compliance. ...

Paragraphs 4 and 5 of IT-286R2 go on to state that an amount is not considered payable if the beneficiary can only enforce payment by either having the trust agreement amended or causing the trust to be wound up. ...