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In this respect, we are of the general view that interest paid or credited by a Canadian resident to a US person might be considered "derived in connection with" a US active business in the following circumstances: the interest is paid or credited in respect of an account payable issued by the US person in the course of carrying on its US active business, the interest payments are in respect of borrowed money used for the purpose of earning income from a business carried on in Canada that is upstream, downstream or parallel to the US active business ("Canadian-Connected Business"), or the interest payments are funded out of the cash flow from such a Canadian-Connected Business. ...

A Crown corporation is not generally considered to be one and the same as Her Majesty, since it is a separate legal person. ...

With the repeal of subparagraph 190.11(b)(ii) of the Act, the Compliance Programs Branch considered the impact of this legislative change to the CRA’s position (as set out in Rulings document 2001-0081267). ...

Therefore, as determined by jurisprudence an election filed with a late 2009 tax return will be considered valid, and as determined by jurisprudence the law does not provide for a late or amended election to be filed as a result of an audit adjustment. ...

Note that any specialized equipment added to the automobile to meet the requirements of a disabled person or for employment purposes, such as cellular phones, two-way radios, heavy-duty suspension, and power winches, are not considered to be part of the automobile's cost for purposes of calculating the standby charge. ...

In situations where some proportion of shares is being replaced with borrowed money, only the capital of those shares, computed on a pro-rata basis, would be considered to be replaced with the borrowed money. ...

If a member pays monthly or yearly dues, these are generally considered to be for "services" the member received and are not added to the adjusted cost base of the membership. ...

We also noted that whether or not a particular employer's self-funded disability insurance plan would be considered as an insurance plan would require a finding of fact that could only be made on a case-by-case basis. ...

The tax preparer was unable to obtain any firm details concerning the nature of the payment, although he thinks there was some indication that it was considered to be a payment of capital out of the trust referred to in the NFA. ...

In such a case, the extended meaning of "carrying on business in Canada" would have to be considered. ...