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Accordingly, the look-back CDE would be considered to be incurred in 2003 for purposes of the $1 million in s. 66(12.602)(c). ...

Each case will be examined "to determine whether the duties vested in a particular nominee corporation or a trust referred to as a bare trust are sufficient to be considered managerial or operational control. ...

1994 Canadian Tax Foundation "Comments on Withholding Tax Rules on Imported Software" 9430560-- summary under Subparagraph 212(1)(d)(vi) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(vi) "The right to make back-up copies as provided by the Copyright Act is not considered a right to produce or reproduce.... ...

Income Tax Technical News No. 33, 16 September 16 2005-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 PE factors including legal control of site There are numerous factors to be considered in making a determination as to whether a permanent establishment exists, one of which is the legal right to exercise control over a place of business. ...

XIL (No. 9639150)-- summary under Subsection 69(11) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(11) s. 111(4)(e) gain within 3 years engaged s. 69(11) Where a taxpayer contributes property with an accrued gain to a loss corporation on a rollover basis and then, prior to the expiration of the three-year period, an unrelated third party acquires control of the loss company and elects under s. 111(4)(e) to step-up the cost base of the previously-transferred property, the deemed disposition under s. 111(4)(e) will be considered to be a disposition for purposes of s. 69(11). ...

All or substantially all is considered to be at least 90% of the property used in carrying on the business. ...

31 August 2004 Headquarter Letter- RITS 50657-- summary under Section 23 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 23 In indicating that legal services provided to a non-resident manufacturer to defend it against product liability claims would be zero-rated, the Directorate stated that: "Legal services supplied to a manufacturer to defend against a product liability claim are not generally considered to be directly connected to the product, but rather directly connected to the manufacturer's objective of defending itself against the claim to minimize its potential legal liability. ...

September 1994)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) "A payment as an inducement covered by subparagraph 12(1)(x)(i) to 12(1)(x)(iii) that is received as part of the acquisition of a business will be considered to be an amount coming from the business in question because there is a cause-and-effect relationship between the payment and the business. ...

7 August 1991 Memorandum (Tax Window, No. 7, p. 7, ¶1388)-- summary under Subsection 118.5(1) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1) Where a student taking courses leading to a post-graduate degree in business management is required to attend the university for only a few weeks in the year but is required to apply in a work environment the advance management techniques being learned and to maintain contact with other students and the tutors through a computer and through the submission of assignments by correspondence, the student will be considered to be in full-time attendance for purposes of s. 118.5(1)(b). ...

Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Use of a Partner's Assets by a Partnership"-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Where a property is acquired by a partner for the purpose of making it available to the partnership to be used in carrying on the business of the partnership, that property will be considered to have been acquired by the partner for the purpose of earning income if the partnership business is carried on with a view to profit, notwithstanding that the partner does not charge rent to the partnership. ...