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The Directorate stated: [A]lthough LLC generates business income, the U.S. taxes paid by the taxpayer are not considered to be business income taxes as defined under subsection 126(7)… because they are not in respect of any business carried on by the taxpayer in the U.S. … To the extent that the U.S. taxes are not used for claiming a foreign tax credit, they may be deducted under subsection 20(12)…. Although what the taxpayer owns is the shares of ULC which is a Canadian corporation, the U.S. taxes paid can be considered to be in respect of such shares such that the deduction under subsection 20(12)… would not be denied because that subsection, unlike subsection 20(11), does not use the clause "that is income from a source outside Canada". ...

., as long as the services are not considered to be “commercial services,” i.e., if the shipping services are not performed by a freight carrier pursuant to Sched. ... If the service supplied is a service of shipping the property that is not provided by a carrier, the service may be considered to be a commercial service in respect of the goods. ...

Need claim only 1 exemption (paras. 3.2, 3.3) When filing a return, an owner need only claim one out of a number of applicable exemptions – although, in light of s. 47(2), the exemptions in s. 6(7)(c) to (f) may be considered less desirable. ... Registered owner until sale reflected on title (para. 3.5) Where the closing of a sale occurs in late December and the documents for transfer of the registered title are submitted at that time, but not processed by the provincial land titles office until the next year, such affected owner is considered to still be the owner on December 31 and must file a return and pay tax if not exempted. ...

The fact that a supplier may be reimbursed for shipping costs does not affect whether a supplier is considered to have retained a common carrier or consignee on behalf of the recipient. 16. A supplier that merely contacts a common carrier or consignee to indicate that the good is ready to be transported pursuant to an arrangement that has already been established by the recipient with the carrier or consignee, or that is merely made aware of such an arrangement, is not considered to have retained the carrier or consignee on behalf of the recipient. ...

As a result, where the real property is both situated in Canada and outside Canada, the proportion of the supply of the intangible personal property that relates to the real property that is situated in Canada is considered to be made in Canada, while the proportion of the supply of the intangible personal property that relates to the real property that is situated outside Canada is considered to be made outside Canada. 30. ...

X would be considered to be making a sale of the interest in the residential complex. … If Mr. ... X, however, is considered to be a builder in his own right (for example, at the time of entering into the agreement of purchase and sale, he did so for the primary purpose of selling the interest or the house itself), tax would be payable by the Vendor calculated on the value of consideration ($100,000) for the supply. ...

Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) Identification of loan or debt 2.9 Revolving credit, such as a line of credit or a credit card, is generally considered to be in the nature of a loan or debt, so that s. 80.4(2) can apply to the revolving credit. 2.10 In the absence of a written agreement, there must be convincing evidence that a loan or debt exists. ... No netting without set-off 2.37 Generally, a deemed interest benefit under s. 80.4(2) cannot be avoided by simply netting an amount due to a shareholder with an amount due from that shareholder, given that a loan is only considered to no longer exist after its actual cancellation or extinguishment. ...

.- Q.18-- summary under Subsection 230(1) Summary Under Tax Topics- Income Tax Act- Section 230- Subsection 230(1) Electronically-produced data generally is considered to be "records". ...

Generally, the supply of a charter flight to a third-party charterer is considered to be a supply of a passenger transportation service. ... Single v. multiple supply A ferry flight is generally considered to be an input to a passenger transportation service.... ...

Generally, upon entering into an agreement for the construction and sale of a new house, the first purchaser is considered to have acquired an interest in the house. For GST/HST purposes, the assignment of the agreement to the assignee purchaser is normally considered to be a sale of the first purchaser's interest in the new house. ...