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If the debt is considered on account of capital, section 80 of the Act may apply. ... considered the debtor's gain on the settlement to be a gratuitous forgiveness in order to keep British Petroleum in business;? ... The Queen 2000 DTC 9065 (FCA) considered the reasoning of the Courts in the earlier mentioned cases. ...

A4 Yes, if a portion of the revenue generating fishing activities are carried on on a reserve, a portion of the business income would generally be considered exempt from taxation. ... The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ... In our view, for an Indian band to be considered a municipality in Canada, it would have to demonstrate that it fits within the facts of the Otineka case.- 8- ...

These other assets would be considered acquired by the mortgagee for all purposes of the Act. ... As noted the right to redeem by the mortgagor is considered conditional on payment being made on the due date. ... If the mortgagee acquires the property on its own account as a third party purchaser then the mortgagee will be considered to have acquired an asset. ...

The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ... Only these lands are considered to be "reserves" in Alberta. ...

Accordingly, in the situation described, both the trees and the logs may qualify as the particular property referred to in the ITC recapture rules and subsection 127(32) of the Act, since each are considered a tangible property. ... In general, for a property to be considered to be acquired, an element of beneficial ownership must exist (possession, use, risk, and control). ... Thus, in our view, if the costs are considered an amount paid to acquire the particular property from a transferor of the particular property, then they would not be considered to be amounts paid to “maintain,” “modify” or “transform” the particular property. ...

It is conceded that the Procurements Rights would be considered property within the meaning of "property" in s. 248(1). ... Treaty The representatives also considered whether the PLF falls within the definition of a royalty in Article XII(4) of the U.S. ... (footnote 26) This portion of the PLF would be considered a royalty for the purposes of Article XII of the U.S. ...

In our opinion, assuming the royalties are not deductible by the BD Partnership in computing its income from a source in Canada, by virtue of paragraph 212(13.1)(a), the BD Partnership will not be considered to be a person resident in Canada for purposes of Part XIII of the Act.  ... The opinions expressed herein are not advance income tax rulings and, in accordance with paragraph 21 of Information Circular 70-6R2 dated September 28, 1990, are not considered binding on the Department. ...

28 May 2015 Internal T.I. 2015-0564591I7- Ontario CMT mark-to-market accounting adjustments CRA Tags Ontario Regulation 37/09 Ontario Taxation Act 57(1) Principal Issues: Whether certain liabilities denominated in a foreign currency are considered specified mark-to-market property for purposes of computing adjusted net income for CMT purposes. ... May 28, 2015 Rajan Tharmarajah Lita Krantz Large Case File Auditor, Manager Toronto Centre TSO, Deferred Income Plans, Section 44 1 Front Street West, Income Tax Rulings Directorate Toronto, ON M5J 2X6 Legislative Policy Regulatory Affairs Branch 2015-056459 Ontario CMT- mark-to-market accounting adjustments This is in response to your request for a technical interpretation as to whether a corporation's account payables denominated in a foreign currency are considered specified mark-to-market property for Ontario corporate minimum tax (CMT) purposes under the Taxation Act, 2007 (the "TA 2007"). ...

19 December 2012 Internal T.I. 2012-0472761I7- Definition of person in respect to a province Principal Issues: Is a province considered a person for the purposes of section 231.2 of the Income Tax Act (the "Act")? ... In our telephone conversation on December 17, 2012, you clarified that you would like confirmation that Her Majesty in right of a province (i.e. a provincial government) is considered a "person" for the purposes of section 231.2 of the Income Tax Act (the "Act"). ...

Where the details of the waiver also provide for a refund as a reasonable outcome of the audit, the refund request may be considered to have been made as part of the waiver and the Minister may issue the refund. ... A blanket waiver without sufficient details of the transaction or potential overpayment would not be considered a valid refund request. ...