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[C]ertain matters listed in subsection 176(1) of the Canada Business Corporations Act entitling the holders of shares of a class or series to vote separately as a class or series are not considered for purposes of determining whether a person holds qualifying voting control of the corporation. ...

17 June 2025 STEP Roundtable, Q.2-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership trustee are not owners of shares in the corpus CRA indicated that trustees are not considered to be owners of the shares held by the trust in the context of the rules in ss. 84.1(2.31)(d) and (e) and 84.1(2.32)(d) and (e) placing restrictions on the ownership of shares by parents in the purchaser corporation of their children or the subject corporation sold by them. ...

September 1994)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where an employee signs a lease directly with a garage and the employer agrees to pay the garage for so long as the employment continues, the payments by the employer will be considered to be part of the employee's remuneration under s. 5(1) or 6(1)(a). ...

If, on the other hand, the transactions are designed to deliberately shift income or loss between provinces, provincial concerns will have to be considered. ...

.- Q.54-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Prepaid expenses relating to an active business of the corporation could be considered as an asset used principally in an active business provided that their amount is reasonable, having regard to all the circumstances, and they were incurred in the normal course of the business. ...

HQR000265-- summary under Subsection 272.1(2) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(2) GST on cost incurred in acquiring interests in a limited partnerships would not be eligible for tax credits given that "where a member of a partnership acquires or imports property or services related to the raising of funds that the member will use to acquire an interest in a partnership, such property or services will not be considered to have been acquired or imported for consumption, use or supply in the course of activities of the partnership. ...

The part of what otherwise would be a residential building that is leased for business use is not considered to be reasonably necessary for the use and enjoyment of the building as a place of residence. ...

29 July 1992 Memorandum (Tax Window, No. 21, p. 4, ¶2037)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Two unrelated individuals each holding ½ of the shares of a corporation will not be considered to act in concert simply because the consent of both is required before the corporation can undertake any action. ...

The non-resident would not be considered to be carrying on business in Canada provided that the contract for the sale of the compact discs to the distributor by the non-resident was concluded outside Canada. ...

September 1994)-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation Where a corporation's fees under service contracts are paid in advance and such funds are invested in term deposits, the term deposits could be considered to be used in its business if they satisfy RC's general requirement that the assets be really used and risked in the business, and if they have been so invested in anticipation of a possible repayment of the fees paid in advance. ...