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The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Accordingly, a series of transactions that results in the transfer of the benefit of the losses, deductions or other amounts from one corporation to a corporation with which it is not affiliated will generally be considered to result in an abuse having regard to the provisions of the Act read as a whole within the meaning of subsection 245(4). ...

It is now our position that where a property is acquired by a partner for the purpose of making it available to the partnership 1 to be used in carrying on the business of the partnership, the property will be considered to have been acquired by the partner for the purpose of earning income if the partnership business is carried on with a view to profit, notwithstanding the fact that the partner does not charge rent to the partnership. ...

When the trustees exercise this right during the year without paying property in kind and without distributing funds before the end of the year, an amount will be considered payable within the meaning of subsection 104(24) if a promissory note is issued and is payable on demand without restriction. ...

A taxpayer who has shares issued to his spouse or children by a corporation, as described in Kieboom, will be considered to have disposed of property and will be deemed to have received a consideration equal to the fair market value of the property under subparagraph 69(1)(b)(i). ...

CALU- Conference for Advanced Life Underwriting (2004) Question 8 Corporate-Owned Life Insurance In a technical interpretation letter dated December 15, 1998 (E9824645), the Agency considered the situation where Parentco is the beneficiary of an insurance policy on the life of its controlling shareholder, and Subco, a wholly-owned subsidiary of Parentco, is the owner of the policy and pays the premiums under policy. ...

Paragraph (d) of the definition of "disposition" in subsection 248(1) provides that a disposition includes a payment that can reasonably be considered to have been made because of the taxpayer's capital interest in the trust, except where paragraph (h) or (i) of that same definition apply. ...

Would CCRA elaborate on the factors to be considered in determining whether paragraph 95(2)(b) applies? ...

The definition of “permissible distributions” in paragraph 8502(d) of the Income Tax Regulations (“ITR”) seems to provide that the portion of the IPP minimum amount that is not described as a “payment of benefits in accordance with the plan as registered” is considered to be a “permissible distribution”. ...

It is considered that since a partnership is not included in the definition of taxpayer, then subparagraph 66.1(6)(a)(v) cannot apply to the partnership. ...