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The consistency principle, simply stated, refers to the requirement to use the same accounting principles from one period to another. 3 A change in an accounting principle to a more preferred method results in inconsistency, however, such a change is acceptable provided the effect of the change is disclosed and, where applicable, prior period adjustments are made. 3 The application of the consistency principle in valuing inventory for tax purposes was considered in The Queen v. ...

If the paying affiliate (CCo in this case) does not have sufficient exempt surplus or taxable surplus, the dividend will be considered to be paid from CCo's pre-acquisition surplus. ...

In arriving at this conclusion in the context of the facts submitted, we considered the application of paragraph 5901(2)(b) and subsections 5901(2.1) and (2.2) of the Regulations, taking into account the coming-into-force and transitional rules set out in subsection 79(2) of Bill C-48. ...

For the purpose of paragraph 94(3)(g), we are on the opinion that the amount of deemed dividend is considered to be included in the total income of the Estate pursuant to paragraph 12(1)(j) and 82(1)(e). ...

In our view, however, a qualifying period is only considered to commence on the first day an employee performs his duties of employment outside Canada. ...

Position: The right to cut Christmas trees, which is for a limited period, is considered Class 14 property. ...

The property would not have an acquisition cost for the purchaser and the consideration for that part of the deal would be considered CEE if the expenses otherwise qualify. ...

Further, providing a key service traditionally offered by the provinces or territories such as social services, overseeing of the environment, health services, or education is generally considered to constitute performing a function of government. ...

General anti-avoidance rule in section 245 of the Act In The Queen v Mackay et al (“Mackay”) 2008 DTC 6238 FCA, the court stated as follows: This appeal is a consolidation of twelve appeals from a judgment of Justice Campbell of the Tax Court of Canada (2007 TCC 94) involving transactions similar to those considered in Mathew v. ...

Position of the XXXXXXXXXX TSO As the Support Agreement contains no provision allowing the Wife to change the arrangement and require any of the 2005 third-party amounts to be paid directly to her to do with as she wishes, the Wife is not considered to have discretion as to the use of the amounts. ...