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It is our view that the corporation can be considered to be "organized...exclusively for any... purpose other than profit" within the meaning of that term in paragraph 149(1)(d) of the Act by virtue of the terms of its Memorandum of Association. ... The bulletin further states that such an association is normally considered to be an extension of the member's sales organizations and will be considered to be carrying on a normal commercial operation. ... We also note that, if, in fact, the status of the corporation has changed, subsection 149(10) of the Act would be applicable at the time of the change with the result that the corporation will, among other things, be considered to have disposed of and reacquired all of its assets at fair market value immediately prior to such change. ...

We would agree that an entity must be considered a person pursuant to the Act for the provision to apply. ... The court also considered the argument based on the definition of employment in the Act. ... Regarding the BC crown corporation, the aforementioned definition of person specifically includes "any corporation", so we cannot understand an argument that crown corporations are not considered persons under the Act. ...

Principal Issues: Are the ‘administration fees’ paid by an employer pursuant to paragraph 65(1.2)(b) of the Employment Standards Act (ESA) of Ontario considered a reimbursement of the employee's legal fees? ... Costs of disbursements that are related to providing legal services would be considered part of legal expenses. ... Legal expenses are considered to include amounts paid for services that are of a legal nature to the extent that they pertain to the domain of law. ...

As a result of a Human Rights Tribunal decision, this program was considered discriminatory against individuals who, because of a disability, could not use public transit. ... Whether this provision applies is a question of fact which depends on whether the transitional benefits paid under the British Columbia Benefits Act would be considered to be paid under a project sponsored by a government in Canada, whether the financial incentives can be considered earnings supplements, and whether they can be considered to have been paid to encourage individuals to obtain employment. ...

The milk quota owned by the partnership is considered to be an "eligible capital property" within the meaning of that term assigned by section 54 of the Act. ... However, since more than 50% of the FMV of the partnership's property is made up of the milk quota it appears that the partnership interest would not, but for the issue in question, be considered as a "taxable Canadian property" under subparagraph 115(1)(b)(vii) such that Mr. and Mrs. A would have been considered to have disposed of their respective partnership interests pursuant to paragraph 128.1(4)(b) of the Act. ...

Generally, a motor vehicle allowance is considered to be reasonable if all of the following conditions apply: The allowance is based only on the number of business kilometres driven in a year; The per-kilometre rate is reasonable; and An employee is not reimbursed for expenses related to the same use of the vehicle. It has been the Canada Revenue Agency’s long-standing position that travelling between an employee's principal residence and their regular place of employment, irrespective of the distance, is personal travel and is not considered to be travel in the performance of an employee’s duties. In addition, even though the kilometre rate provided under the XXXXXXXXXX Directive is based on the number of kilometres driven, generally, in order to be considered reasonable a per-kilometre rate should be designed to cover an employee’s out-of-pocket costs for the use of the motor vehicle. ...

In the scenario your have provided, it is worth noting that the 2018 court order must also be considered. ... If the payments under the 2018 court order reflect actual amounts owing under the original order, the formula in paragraph 60(b) must be considered when determining whether payments are deductible in the year. ... Any balance paid in the year is then considered to be for child support payable for earlier periods or for support of the recipient, as the case may be. ...

A corporation's business will be considered to have been carried on in Canada if at least 50, of its employees are engaged in the business in Canada or at least 50, of its salaries or wages are paid for services provided in Canada in respect of the business. If the corporation is part of a group of related corporations, the combined services of their employees and the combined salaries and wages paid must be considered in making this determination. ... Due to the detail and complexity of the regulations regarding these issues, the foregoing comments are intended to only provide an overview of the relevant provisions and should not be considered as comprehensive or all inclusive. ...

Based on the above, you have asked for our opinion on whether the husband and wife are considered a partnership and, if so, whether they are entitled to claim the deduction under subparagraph 110(1)(f)(iii) of the Act if they meet the requirement of "residing with" the individuals being cared for. ... In this respect we have considered four different types of business operations. 1.      ... It is our belief that in most cases, the physical arrangements will reflect the intent and relationship of the owners and residents vis-a-vis their residing with each other. 21(1)(b) With respect to your question as to whether the husband and wife are considered a partnership, we are unable to give a definitive reply as we do not have enough information concerning the situation to make that determination.  ...

Realco will be considered a small business corporation (SBC) pursuant to the definition in subsection 248(1), since it is a Canadian-controlled private corporation (CCPC) and all or substantially all of the fair market value of its assets are used in an active business carried on in Canada by a corporation related to it.  A share of Realco will be considered a QSBC share by virtue of the definition in subsection 110.6(l), since (I) a share of Realco is a share of a SBC owned by an individual, (2) throughout the immediately preceding 24 months the share was not  owned by anyone other than the individual, and (3) throughout the preceding 24 months more than SOS of the fair market value of its assets were attributable to assets used in an active business carried on in Canada by a corporation related to it.  ... Opco will be considered a SBC pursuant to the definition in subsection 248(1), since it is a CCPC and all or substantially all of the fair market value of its assets consist of a combination of  (1) assets used in an active business carried on by it in Canada, and (2) a note issued by a connected SBC (being Realco).  ...