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(c) Would interest paid on a guaranteed investment certificate or on a term deposit only once on maturity be considered to be paid on a periodic basis? ... (b) See paragraph 19.1 of IT-212R3 (c) Since interest accrues on a daily or other periodic basis, such interest is considered to be payable on a periodic basis even though it may not be due until maturity (d) Undeclared dividends would not be included in the deceased individual`s income under subsection 70(1). ... For tax purposes, a taxpayer is generally considered to have disposed of each of his properties upon death; accordingly, the deceased's estate would be required to include in its income dividends declared after the deceased individual's death. ...

In such circumstances, an amount donated by the individual to the qualified donee to enable the donee to pay the premiums in respect of that policy is considered to be a gift for the purposes of the Act. Where the individual pays the premiums under the policy directly to the insurance company at the request of, or with the concurrence of, the donee who owns the policy, the amount paid is also considered to be a gift for the purposes of the Act. ... The CRA has previously noted the possibility that a portion of the life insurance premiums paid by an individual under a split dollar or shared ownership arrangement may be considered a gift under the proposed split-receipting legislation. ...

Question Will Article IV(6) of the Treaty apply such that the interest on the Debt that is deemed to have been paid pursuant to paragraph 78(1)(b) of the Act will be considered to have been derived by XCo for the purposes of the Treaty? ... In the situation described above, the income referred to in Article IV(6) of the Treaty is the Canadian-source interest that is payable under the terms of the Debt and that is considered, under the taxation laws of the United States, to be derived by XCo through LLC. Therefore, provided that the treatment of the interest under the taxation laws of the United States is the same as its treatment would be if the interest had been derived directly by XCo, such interest will be considered to have been derived by XCo for the purposes of the Treaty. ...

This is in reply to the memorandum of August 14, 1997, from Kathie Cameron requesting our views as to whether a promissory note received by a taxpayer would be considered payment of a debt or evidence of a debt, for purposes of subsections 28(1) and 76(1) of the Income Tax Act ("the Act"). ... Whether a promissory note is considered to be payment of a debt and therefore absolute payment, or evidence of a debt such that it is conditional, is a question of fact. Although it is usually considered that a creditor has accepted a promissory note as conditional payment or as evidence of indebtedness, in the appropriate circumstances, the promissory note may be accepted as absolute payment and the debtor will be considered to have paid the debt. ...

An anti-avoidance rule (subsection 125(5.2)) deems corporations which are related but not associated to be associated for the purposes of this rule where it may reasonably be considered that one of the reasons for a loan or transfer was to reduce investment income and increase the amount which can be claimed under the small business deduction. ... Whether subsection 125(5.2) would apply in any given situation remains a question of fact that can only be made once all the relevant facts of a particular situation are known and have been fully considered. However, if it may reasonably be considered that one of the reasons that the payment of dividends was made was to reduce the adjusted aggregate investment income as determined in paragraph E of paragraph (5.1)(b) in respect of Opco, or of any corporation with which Opco is associated, then in our view the anti-avoidance rule in subsection 125(5.2) could apply. ...

Reasons: The CRA does not intend to generally substitute its judgement of what would be considered a reasonable amount where taxpayers have made a good faith attempt to do so based on the reasonableness factors. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 3. ... While the issuance of a promissory note by a trust to a beneficiary may be an acceptable method of providing evidence of an amount made payable to a beneficiary for the purposes of subsection 104(13), such evidence does not have any impact on the determination of whether such income would otherwise be considered split income of that individual. ... If the beneficiary has attained the age of 24 years before the particular year, the “reasonable return” exception provided in subparagraph (g)(ii) must be considered for such interest income. ...

However, an employee whose only physical presence at the employer's establishment is limited to attending a few meetings or information sessions in the course of a given year will not be considered to report for work there. ... Thus, to be considered as reporting to his employer's establishment, an employee must physically present himself there on a recurring basis. To this end, an employee would be considered to report to his employer's establishment on a recurring basis if he attended a half-day of work per week, i.e. more than 4 hours. ...

Question (a) Provide examples of transactions that might be considered to be the stripping of corporate assets. ... (a) Could you please provide some further guidance with respect to what transactions might be considered to be the stripping of corporate assets. ... Furthermore, in cases where the refreeze transaction is not implemented on a FMV basis, the application of subsection 51(2), 86(2) or paragraph 85(1)(e.2) would also have to be considered. ...

Application of GAAR should be considered. Reasons: The legislation CLHIA ROUNDTABLE- MAY 2009 Question #5 Criss-Cross Buy Sell Arrangement and Policyholder Tax Facts Two shareholders (A and B) of a corporation enter into a buy-sell agreement where the criss-cross purchase method is used. ... Subsection 148(7) of the Act further provides that B will be considered to have acquired the policy for an amount equal to that same "value". ... The possible application of section 245 of the Act should also be considered. 2009-031667 Alison Campbell May 1, 2009 ...

Cash and cash equivalent are considered to be used principally in a business if their withdrawal would cause the destabilization of the financial aspect of the business. 3. ... The cash balances which accumulate and which are, thereafter, used in accordance with annual seasonal fluctuations of a permanent business will usually be considered used in a business, but a continuous balance which exceeds the reasonable working capital needs of a corporation will not usually be considered used to this end. 5. ... The CRA is also of the opinion that cash or cash equivalent which is only used to pay the current portion of long term debt is not usually considered to be used in a business. ...