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Furthermore, in some instances, where the agreements provide for the delivery of an actual physical commodity, the supply is not a financial instrument….Therefore, the Brokers providing the services in respect of these contracts to USCO and CANCO would not be considered to be "arranging for" financial services and consequently, the supplies provided by the Brokers would not be financial services. ...

14 July 1999 Memorandum HQR0001244-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) target circular costs eligble "Property or services acquired... by a corporation in fulfilling obligations under a securities or corporations Act in producing circulars for shareholders concerning takeover bids, would generally be considered to have been incurred for the purpose of making supplies for consideration in the course of the corporation's endeavour.... ...

It is also considered that the joint ownership of a home by a taxpayer with her spouse after January 1, 1990 will not result in disqualification if subsequent to that time she was separated from her spouse and did not inhabit the house, as referred to in s. 146.01(2)(a.1). ...

September 1994)-- summary under Subsection 22(1) Summary Under Tax Topics- Income Tax Act- Section 22- Subsection 22(1) In considering a situation where a corporation had two divisions, one of which did printing and the other which did photo typesetting, and all the assets of the first division were sold to another corporation which continued the operation in the same manner and under the same name, RC stated that "the fact that the corporation that has acquired the assets used in the printing division can be considered to be carrying on a separate business does not mean that the vendor corporation was operating its two divisions in the form of two separate businesses. ...

CBA National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 27-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex retirement home "common area" On the sale of a retirement home containing residential condominium units (or which was a multiple unit residential complex) the residential complex would be considered to include the cafeteria, recreational centre and basement area for storage lockers if they were included in the common area of the condominium plan and were for the exclusive use of tenants. ...

An amount designated to a beneficiary under subsection 104(21) must reasonably be considered to be part of the amount included in the beneficiary's income for that year under any of the provisions referred to...above.... ...

It is not based on the place where title to the goods transfers....If an Incoterm is used...the place where legal delivery of the goods occurs can be determined by reference to the place where delivery is considered to occur under that Incoterm. ...

.- Q.13-- summary under Paragraph 95(2)(f) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f) If at the time Canco acquired FA1 for $100 which in turn owned FA2, the shares of FA2 had a fair market value of $100 and a basis of $1, and the shares of FA2 decline in value to $1 and the decline subsequently is reversed, then if the shares of FA2 are sold for $100, the portion of the gain that may reasonably be considered to have accrued during the period that FA1 was not a foreign affiliate of Canco would be the unrealized gain that existed at the time that FA1 became a foreign affiliate of Canco, i.e., $99. ...

Annual Conference, Q. 17 (January- February 1993 Access Letter, p. 56)-- summary under Specified Member Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Specified Member Partners whose only involvement in the partnership business is to answer surveys and to meet from time to time with persons in charge of the SR&ED projects being undertaken by the partnership in order to be informed and to have decisions and budgets approved, would not be considered to be specified members. ...

25 March 1991 Memo 7-4727-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US withholding on share redemption was income tax US withholding taxes paid on the redemption of preference shares of a US subsidiary qualified as income or profits taxes within the meaning of s. 126(7)(c) given that under U.S. income tax law all distributions of property from a U.S. corporation are considered to be dividends unless there exists certain prescribed conditions. ...