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Unless the shares of XXXXXXXXXX were jointly owned by XXXXXXXXXX to begin with, XXXXXXXXXX will not be considered to have acquired any interest in them as a result of the application of the OFLA or the Agreement. ...

For example, it would not be necessary for subsection 49(3) of the Act to deem the granting and the exercise of the option not to be dispositions of property (for purposes of the capital gains rules) if it was not considered a disposition of property to begin with. ...

In reaching our conclusion, we considered whether the Excess Foreign Tax could be allocated entirely to the 2001 taxation year, or whether it had to be allocated in equal portions between each of the relevant taxation years, such that only $500 was actually available in 2001 as a 20(12) Deduction. ...

The wage subsidies portion of employment and vocational supports, described in paragraph e) of section 8.9.2 of the Program Policy, would not be considered "social assistance". ...

In accordance with the comments in paragraph 5 of Interpretation Bulletin IT-239R2, if a debt bears interest at a reasonable rate, the debt will generally be considered to be acquired for the purpose of gaining or producing income. ...

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 (for more information regarding paragraph 12(1)(c) and subsection 12(4) of the Act, please refer to Interpretation Bulletin IT-396R, a copy of which is enclosed herewith). ...

A debt is considered bad for the purpose of section 50 of the Act only when the whole amount is uncollectible or when a portion of it has been settled and the remainder is uncollectible. ...

We cannot ignore the importance of the relationship of the borrower and the lender in determining whether an interest rate is considered to be a reasonable one for the purposes of subsection 17(1) of the Act. ...

As a result, it appears that generally an artist can be considered an artiste. ...

These expenses could then qualify for inclusion in CEE pursuant to paragraph (a) thereof if they could be considered to be "any expense... incurred by the taxpayer... for the purpose of determining the existence, location, extent or quality of an accumulation of petroleum or natural gas... in Canada". ...