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Principal Issues: Whether interest on an obligation is considered to be paid when a new obligation is issued which principal amount inludes accrued interest on the original obligation Position: no Reasons: The new note is issued precisely because the interest has not been paid. ... Basically, your query concerns whether the accrual of the interest together with the execution of a new note should be considered a payment of that accrued interest. If it can be considered to be a payment of the accrued interest, then the withholding tax should be paid at the time If it cannot be considered to have been paid, then a portion of interest charged on the new principal amount of the loan subsequent to that time should be considered to be on account of compound interest and deductible pursuant to paragraph 20(1)(d) of the Act when paid. ...

Prior to the wedding and following a divorce the parties to the union are considered to be "single", while during the period of the union the parties are considered to be married to each other. ... Q. 1If a common-law relationship is severed, are the individuals involved considered to be "single" or "separated"? ... Where the particular time being considered is within the 90 day period they would continue to be considered married, but separated, at the particular time unless the separation extends past the 90 day period. ...

Primary purpose of trip must be considered for work related stop on way home or regular workplace. ... These particular trips are not considered to be of a personal nature. ... An employee's drive to and from an airport for a business trip would likely be considered employment related. ...

A damage/compensation receipt could be considered as on account of income under section 9 of the Act if such receipt is intended to compensate the recipient for its loss of profits. ... If that is the case, such a damage/compensation receipt would be considered as an "eligible capital amount" for the purpose of section 14 of the Act. ... According to the Simon's Direct Tax Services, a right to provide services under a contract would be considered as a property (i.e., unfortunately this issue was never argued and considered by the Courts in the case of Alan M. ...

Our Comments If the participating interest is considered as a distribution of profits, then the interest payment by a taxpayer is not a deductible expense.  If the participating interest is considered as an expense of doing business, then the interest payment by a taxpayer may be considered as a deductible expense.  ... Similarly, if the circumstances of the situation can be considered to have normal commercial terms, is not guaranteed by the general partner or the partnership and the "lender" has full recourse, the at-risk amount would not be reduced and its features would not be considered to be a prescribed benefit.  ...

Whether fees paid for the use of a dormitory room would be considered rent for purposes of computing the clergy residence deduction? ... You have also asked whether the fees paid for the use of a dormitory room would be considered rent for purposes of computing the clergy residence deduction. ... However, technical interpretation (TI) 2012-045596 considered the meaning of this phrase for purposes of paragraph 8(1)(c) of the Act, and noted that a principal place of residence is generally considered to be the place where an individual regularly lived, slept, received mail, etc., and in some cases, where the individual's immediate family also resided. ...

In addition, due to the requirement to establish gross negligence, the penalties provided by 163(2) are not being considered in these situations. ... Where a prescribed form received by CRA is considered invalid, it follows that it has not been filed as and when required by the Act. ... In that case it was stated that where a taxpayer has only provided limited information in a form, the form is considered to be invalid. ...

XXXXXXXXXX also argues that according to IT-128R paragraph 4(b) expenditures made to restore property to its original condition are considered to be current expense. ... The clean-up expenditures considered at the present time are incurred in respect of XXXXXXXXXX 2. ... XXXXXXXXXX 9.Revenue Canada has determined that a landlord's costs to remove asbestos are considered capital in nature rather than current expense. ...

Whether a motor home is considered to be a qualifying home. 2. Whether a motor home is considered to be a principal place of residence. ... The first issue is whether the motor home is considered to be a qualifying home and the second issue is whether it is considered to be a principal place of residence. ... Therefore, a motor home is not considered to be a mobile home and in turn a housing unit for purposes of the HBP. ...

A particular site at which an employee reports to work for an extended period of time will likely be considered a RPE for that employee. ... The executive’s residence will not be considered a point of call if the residence is the pick-up and drop-off point every day. ... As noted above, an employee may have more than one RPE and the office of the employer may also be considered a RPE for the driver. ...