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Individuals claiming double tax relief and relying on the Anson v HMRC decision will be considered on a case by case basis. ...

15 November 2011 Headquarters Letter Case No. 135608-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) Where a "capital pool company" raises capital pursuant to a prospectus on a blind pool basis in order to invest in a company or make an asset acquisition, it will not be considered to be engaged in commercial activity (and, therefore, will not be entitled to register) until it has identified a particular asset acquisition. ...

15 November 2011 Headquarters Letter Case No. 135608-- summary under Paragraph 240(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(3)- Paragraph 240(3)(a) commencement of preliminary commercial activity Where a "capital pool company" raises capital pursuant to a prospectus on a blind pool basis in order to invest in a company or make an asset acquisition, it will not be considered to be engaged in commercial activity (and, therefore, will not be entitled to register) until it has identified a particular asset acquisition. ...

Employee did not perform duties-- summary under Paragraph 8(1)(n) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) When an employee repays you, in the same or a later year, for salary or wages received when the employee did not perform his or her duties, the repayment is considered to be a repayment of salary and wages. ...

The tenant is considered to have relinquished a right or rights in respect of a leasehold interest, and thus such an amount represents proceeds of disposition of part or all of the leasehold interest. ...

Where there is no specific statutory procedure, the litigation will be considered to have commenced when the board etc. is made aware of the complainant's intentions. ...

For instance, if as a matter of fact, the right that is supplied could only ever be used from a single location in a single province, then the use of the right would be considered to be limited to that province regardless of whether this is explicitly stated in the terms of the agreement. ...

In a given situation, one of the factors considered in determining what is a reasonable time is the normal commercial practice which would prevail in a similar situation. ...

If a person is designated to be a municipality for particular exempt municipal services that it supplies, the person is considered to be a municipality only for the purposes of the public service bodies' rebate and only for those particular exempt municipal services. ...

IT-153R3 "Land Developers- Subdivision and Development Costs and Carrying Charges on Land"-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) (Para. 13) Costs in respect of installations within a subdivision, which are considered to constitute a component of the cost of the land inventory, include costs of roads, sewers, water mains, street lighting, sidewalks, landscaping and recreational facilities. 14. ...