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For example, if you pay the property taxes, have the right to alter the land, control entry or access to the property, or pay insurance coverage, you may be considered to have possession of the property. ...

.- Q. 11-- summary under Subsection 66.7(3) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(3) Where there is an acquisition of control of Company A thereby causing Company A's resource pools to be successored, and Company A subsequently transfers its resource properties to a partnership electing a nominal amount under s. 97(2), Company A's proportionate share of production revenue allocated to it by the partnership will be considered to be income under, for example, s. 66.7(3)(b)(i)(C) which is eligible for successor pool deductions. ...

17 July 1995 Headquarter Letter File 11635-3-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply When a non-resident sells discs in Canada under a consignment arrangement with a Canadian distributor, the fact that there is a sale from the non-resident to the distributor simultaneous with the sale by the distributor to a Canadian consumer does not necessarily cause the initial contract to be considered to be concluded in Canada. ...

.- Q.35-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) real estate partnership interest Because an interest in a partnership is not considered to be an interest in its underlying assets, a capital interest in a real estate partnership held by a non-resident will qualify as eligible property, although s. 245 could apply where a partnership formed as part of a series of transactions which are designed to circumvent s. 85(1.1). ...

22 November 1991 Memorandum (Tax Window, No. 13, p. 9, ¶1608)-- summary under Subsection 5907(1.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1.1) Provided that the primary and secondary affiliates are going concerns and the intercompany account has been charged with a number of offsetting items, the secondary affiliate will be considered to have paid the primary affiliate for the taxes where their amount has been booked to the intercompany account. ...

.- Q.48-- summary under Paragraph 6(1)(e) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e) An automobile will be considered to be available to the employee where: the employee is absent from the country on business and leaves the automobile at the airport parking lot; he is on holiday and leaves the automobile parked on the employer's premises; the automobile is being repaired at a garage; and he is ill or disabled. ...

7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)-- summary under Subparagraph 20(1)(p)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(ii) A standard distress preferred share ruling is that provided the debt arose from one or more loans made by the specified financial institution in the course of its money-lending business, the debt reacquired by the institution will be considered to have been acquired by it in the ordinary course of its business of lending money for the purposes of ss.20(1)(l) and (p). ...

14 July 1989 Inter-Divisional Memorandum (Dec. 89 Access Letter, ¶1054)-- summary under Subsection 110.7(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.7- Subsection 110.7(1) Even though an individual may be physically absent from the prescribed area while on overseas assignment, he should still be considered as a resident of the prescribed area if that remains the centre of his vital interests, in which case if he claims the overseas employment tax credit, he may also be entitled to the northern resident deduction. ...

"Part I.3, Advances")-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) An advance billing, that remains unpaid at a year end, made with respect to services to be rendered in a subsequent year, would not be considered to be an "advance" (as defined, for example, in Black's Law Dictionary, and in TransCanada Pipelines Ltd. v. ...

10 January 1992 CGA Roundtable, Q. 19, 7-912224-- summary under Paragraph 69(1)(a) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(a) FMV of debt rather than amount owing Where shares are issued by a corporation on the conversion of debt owed by the corporation to a non-arm's length shareholder, the value of the debt rather than its principal amount must be considered as the amount paid to acquire the shares when determining whether the cost of the shares is limited by s. 69(1)(a). ...