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The relationship between the service and the real or tangible personal property must be more direct than indirect for the service and the property to be considered by the Department to be "in respect of" each other for purposes of paragraphs 7(d) and (e) and paragraphs 23(b) and (c) of Part V of Schedule VI. ... The following are examples of services that are considered to be in respect of real property for purposes of Part V of Schedule VI: services physically performed on the real property (e.g., construction and maintenance); services that enhance the value of the real property, affect the nature of the real property, relate to preparing the real property for development or redevelopment, affect the management of the real property, or affect the environment within the limits of the real property (e.g., engineering, architectural services, surveying and subdividing, management services, security services); services related to; the transfer or conveyance of the real property or the proposed transfer or conveyance of the real property (e.g., real estate services in relation to the actual or proposed acquisition, lease or rental of the real property, legal services rendered to the owner or beneficiary or potential owner or beneficiary of real property as a result of a will or testament); a mortgage interest or other security interest in the real property; or the determination of the title to the real property. ...

[W]e would likely conclude that the LP in scenarios 1 and 2 are ILPs and further information would be required to determine if the LP in scenario 2 is no longer considered to be an ILP. With respect to scenario 4, we would likely conclude that the LP is not an ILP and further information would be required to determine if the LP in scenario 4 is considered an ILP at a later time. ...

An organization that is commencing operations, or is considering commencing operations, will be considered to be operated primarily for the purposes of meeting the “operated primarily” requirement if its intent is to primarily offer correspondence courses, or instruction in courses, that develop or enhance students’ occupational skills. ... A sole proprietor, such as a teacher or a coach, who has a contract with a vocational school to provide a service of instruction as one of the sole proprietor’s business revenue streams is not considered a vocational school for purposes of that contract. ...

The medical professional corporations are each considered the employer on a proportionately agreed upon basis in respect of the employees. ... Thus, when that place is situated outside Canada, that person will not generally be considered as being “employed in Canada”. ...

As a result, the net tax remittance that is offset by an amount of the refund or rebate under subsection 228(6) or subsection 228(7) of the Act is considered to have been remitted to the Receiver General on that day. (Note: Generally, in the absence of any other evidence, the day a return or rebate application is postmarked by the post office will be considered as the day the return or rebate application was mailed.) ...

Where a physician who has patients hires a locum to fulfill their duties during their absence, it could be considered that the physician has subcontracted the care to the locum. ... Considering that health care services legislation is of provincial jurisdiction, the rules applying in the province would have to be considered. ...

The acceptance of the loyalty points by Company B or its independent dealers is considered to be the acceptance of a “coupon” as defined in s. 181(1), that is redeemed by a customer for a discount that is applied to the purchase of widgets. 2. ... The redemption of loyalty points by a customer in exchange for a free service provided by Company B or an independent dealer would be considered the acceptance of a coupon, and s. 181(4) would apply where Company B or its dealer accepted the loyalty points. 6. ...

Rather than refundable taxes only being included in income when received, CRA now considers that the portion of refundable taxes that will be reimbursed due to a payment of a dividend before the end of the taxation year will be considered to be a reduction of such taxes paid or accrued (so that the potential safe income is reduced only by the net amount). When a corporation realizes the accrued gain, on a property that it had acquired on a rollover basis in consideration for preferred shares, on disposing of that property, that gain is now considered to contribute to the gain on those preferred shares, so that such gain is to be included in the safe income of the preferred shares. ...

Property included in Class 14.1 (such as a farm quota) is generally considered to be intangible property and, as such, will generally not be former business property. ... While the income received from the partnership for leasing the property is classified as rent, the owner is also considered to be using the property for business purposes as a member of the partnership. ...

. … Where a person receives a direct share of the actual mining payment, or a payment or adjustment that is determined based on the actual mining payment earned by the pool or the operator, the person is generally considered to share in the mining payments. However, where a person earns compensation that is determined based on an estimate of potential mining payments and the amounts are not adjusted to the actual mining payments, the person may not be considered to share in the mining payments. ...