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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. ...

Issue #3 Whether the proposed reassessment of the 2005 taxation year is considered a total loss post CCAA, or whether it would have to be prorated between the pre-filing period and the post-filing period. ...

However, if the taxpayer owns two or more units or lots in the same building with an aggregate capital cost of at least $50,000, all such units or lots in the same building are considered to be a single rental property in a separate prescribed class. ...

In the case at hand, the transactions do not appear to be any more abusive than capital gains crystallization transactions, which are generally not considered to offend tax policy. ...

It is an agreed fact that for US federal income tax and the Canada-US Tax Convention, Canco is not considered to be carrying on business in the US through a permanent establishment ("PE"). ...