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CRA responded: An emission allowance is a right and…is considered intangible personal property. Thus, an option or contract [thereon]…would not be considered an option or a contract for the future supply of a commodity…. …Where the option or contract can only be settled in money it may be considered a financial instrument. ...

IT-392 (Archived) "Meaning of the Term 'Share'"-- summary under Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Share capital of non-share corporation considered to be divided into shares 3. In those instances in which the ownership of a foreign business entity is not divided into units entitled "shares", and in which the foreign business entity is considered to be a corporation, the Department views the foreign business entity as if it has a capital stock of 100 issued shares. Each owner of a beneficial interest in the foreign business entity is then considered to own a number of shares proportionate to his beneficial interest in the foreign business entity. ...

PST 319 "Partnerships" February 2014-- summary under Subsection 151(2) Summary Under Tax Topics- Other Legislation/Constitution- British Columbia- Provincial Sales Tax Act- Provincial Sales Tax Exemption and Refund Regulation- Subsection 151(2) For PST purposes, unless a limited partnership agreement provides otherwise in writing, the general partner(s) is considered to own the partnership's assets. If you acquire a limited interest in such a partnership, you are not considered to be purchasing an interest in the partnership's assets and, therefore, do not need to pay PST. Unless a limited partnership agreement provides otherwise in writing, any transaction involving the limited partnership is considered to be a transaction with the general partner(s). ...

To be considered an individual's place of residence, the place should be used for purposes of habitation or dwelling, but would not normally include an abode of a transient nature. (For example, subject to other factors considered below, short-term hotel accommodation would not normally be considered an individual's place of residence.) ... Rather, it would be considered to be a place of lodging. Words and Phrases place of residence ...

Where one business operation succeeds another the following comments may be of assistance in determining if the two businesses are the same business: (a) where the succeeding business operation is not the same kind as the former, the two operations will be viewed as different businesses at the different times and no other factors will operate to change that view; (b) where a business operation ceases or is disposed of and following this the same taxpayer acquires another business operation of the same kind, the two business operations will normally be considered to be the same business if the second business operation is purchased on or around the same time that the first operation is disposed of or it can be established that a second operation was contemplated at the time of disposition of the first operation; (c) where the succeeding business operation of a corporation is of the same kind, but ownership of the corporation has changed, the two operations will normally not be considered the same business if the first business ceases operation before the second operation begins. ... The sale of all fixed assets of a business is not considered a mandatory requirement for the ceasing of a business if it can otherwise be established to have ceased. 5. When determining whether business operations are of the same kind, the principal factor to be considered is the type of business that a taxpayer is in. ...

Premises leased or licensed to the supplier under an agreement can qualify; and “an establishment staffed by employees of a supplier would generally also be considered to be an establishment operated by the supplier.” ... Individuals’ provision of foster care is not considered to be a commercial activity and, thus, is not subject to GST/HST. ... Where tenants under leases of residential units in a residential complex may acquire optional services for additional fees, such as personal grooming, laundry, and cleaning services, there will be considered to be multiple supplies, i.e., of real property and e.g. laundry services. ...

" In establishing whether a property is used principally for a given purpose, one of the main factors to be considered is the proportion of time that the property is used for that purpose. ... Another important factor to be considered is the proportion of the amount of space rented in relation to the total area of the building.... ... On the other hand, if the services offered (for example, medical care in a nursing home) are such that they go beyond being merely ancillary to the use and occupation of the property, gross revenue derived from such services is not considered to be rent derived from the property. ...

Is the deceased's estate considered to be a contributor to the child's trust or is the only contributor the deceased himself? ... Accordingly, the deceased's estate will be considered to be a contributor to the child's trust. ... Therefore, in the given instance, the deceased is also considered to be a contributor to the child's trust. ...

Is the deceased's estate considered to be a contributor to the child's trust or is the only contributor the deceased himself? ... Accordingly, the deceased's estate will be considered to be a contributor to the child's trust. ... Therefore, in the given instance, the deceased is also considered to be a contributor to the child's trust. ...

Where renewal or extension periods are considered part of the life of the property under the criteria set out in ¶ 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ... Provisions, including force majeure and contingency termination clauses, which may result in an early termination of the life of a property are not considered relevant in determining the life of the property and whether or not the property is for a limited period.... 18. ... A registered industrial design is considered to be a franchise for a limited period and the life of the property on initial registration is 10 years. ...