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The facts of the case indicated that Child could be considered to be a “child” of Individual C during the time that maintenance payments were being made to her. ... However, it seems to us that the requirement can be considered to have been satisfied. The fact that Individuals A and B paid support to Individual C of $XXXXXXXXXX a month would not, in and by itself, preclude the Child from being considered “wholly dependent” on Individual C. ...

One such restriction is that fees are not considered to be ancillary tuition fees if they are paid in respect of property to be acquired by the student (subparagraph 118.5(3)(c)(ii)). ... In our view, a textbook lease arrangement involving lease payments in respect of 1/3 of the value of the textbooks would be reasonable and, accordingly, the lease payments would be considered ancillary tuition fees. ... We would mention that if XXXXXXXXXX provides a student with “free” tuition in the circumstances explained in paragraph 16 of IT-516R2, the student is not considered to have paid any tuition fees eligible for the tuition tax credit. ...

If the guarantee has been given for adequate consideration, it will generally be considered to have been given for the purpose of gaining or producing income. Therefore, if the acquisition of a debt in these circumstances gives rise to a bad debt, any loss arising from a payment required of the guarantor under that guarantee will be considered to be a deductible capital loss within the meaning of paragraph 39(1)(b) of the Act. ... The Department has accepted the decision and it will be considered during the next update of the bulletin. ...

20 April 2021 Internal T.I. 2020-0843351I7- Liquid meal replacement products Unedited CRA Tags 118.2(2)(n); 118.3(1)(a.1); 118.3(1.1); ITR section 570 Principal Issues: 1) Whether the cost of a particular liquid meal replacement product that is prescribed for a patient post lung and throat cancer, would be eligible as a medical expense for the purpose of the medical expense tax credit. 2) Whether consuming the particular liquid meal replacement product may be considered "therapy" for the purpose of the disability tax credit. ... You also ask whether consuming the particular product may be considered “therapy” for the purpose of the disability tax credit (DTC). ... It is our view that being required to consume a particular meal replacement product would be more akin to a dietary restriction or regime and would not be considered therapy as contemplated by paragraph 118.3(1)(a.1) of the Act. ...

The court concluded that, based on the commentary to the 1977 OECD Model, the office had to be considered as a fixed place of business.  ... The court considered that both the collection of data and its analysis were essential business activities of the company.  Since Creole was performing business activities through a fixed place on the platform located on the Norwegian continental shelf, it was concluded that Creole should be considered as having a P.E. in Norway.  ...

Whether providing special event equipment consulting services and selling audio, video, lighting and stage equipment to event hosts would be considered eligible activities described in either or both of subparagraphs (b)(iv) and (xx) of the QTHE definition for purposes of determining whether a particular eligible entity is a QTHE. ... It is a question of fact whether the eligible entity’s activities would be considered eligible activities described in either or both of subparagraphs (b)(iv) and (xx) of the QTHE definition. ... In the situation you described, it is a question of fact whether the eligible entity’s activities would be considered eligible activities described in either or both of subparagraphs (b)(iv) and (xx) of the QTHE definition. ...

The courts recently considered the meaning of the phrase “a municipal or public body performing a function of government in Canada” in Lawyer’s Professional Indemnity Company (footnote 1) (Lawpro). ... Therefore, it is our view that it is considered to be performing a function of government. ... Therefore, it is our view that it is also considered to be performing a function of government. ...

In addition, a portion of the Payments may be considered a reimbursement of an outlay or expense incurred by XXXXXXXXXX. ... Capital Gain or Eligible Capital Amount We have also considered whether the Payments can be considered to give rise to a capital gain or an eligible capital amount. ... The Queen 2008 DTC 4982, Archambault J. considered the conclusions of the Supreme Court of Canada in Canada v. ...

If the shares of the Parent would be TCP had the Parent capitalized its wholly-owned Subsidiary with only equity, then such shares will be considered TCP if the Parent capitalizes the Subsidiary in part with equity and in part with debt.” ... If the shares of the lending corporation would not be TCP had the corporation not made the upstream loan (e.g., if it had kept its internally generated excess funds in a bank account), then such shares will not be considered TCP if the corporation has made the upstream loan. ... Intercompany receivable balances pertaining to loans made to a sister corporation need to be considered on a case by case basis to ascertain if there is an impact on the determination of whether the value of the shares of the particular lending corporation was derived directly or indirectly from one, or any combination of, RCP. ...

The amount owed by the corporation as guarantor is not considered to be a continuation of the corporate loan that had been guaranteed nor a second loan. ... A taxpayer, who makes a payment under a guarantee of indebtedness of a corporation, will generally be considered to have acquired the rights of the creditor in respect of the indebtedness at the time of payment.” ... Consequently, that portion of the borrowed money will satisfy the use test in subparagraph 20(1)(c)(i) of the Act, and the property will continue to be considered a source of income of the taxpayer even though the taxpayer may have disposed of it. ...