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Similarly, a notice in an annual or quarterly report that an eligible dividend has been paid is considered valid for that year or quarter, respectively. ...

.- Q.53-- summary under Share of the Capital Stock of a Family Farm or Fishing Corporation Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Share of the Capital Stock of a Family Farm or Fishing Corporation If throughout an 8-year period that a corporation owns a particular piece of land, the corporation is carrying on a farming business in which one of the qualifying individuals in the definition is actively engaged on a regular and continuous basis, the land will be considered among the eligible properties insofar as the 50% test is concerned during the period of time it was used in the farming business. ...

CRA stated: We are of the view that transactions that are designed to allow a person to acquire a very substantial economic interest in a corporation (for example, perhaps by having both de facto control and a substantial equity interest in the corporation) and to benefit from the corporation's tax losses, without being subjected to the “same or similar” business restrictions in subsection 111(5), could reasonably be considered to result in an abuse having regard to the general policy of the Act against the trading of non-capital losses by unrelated corporations. ...

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. ...

CRA declined to comment on whether the supply of memberships or points was a supply of intangible personal property or real property in the absence of being provided with the relevant agreements other than to say that if the supply of points gave the recipient only the right to use real property, the supply would be considered as a supply of real property for GST/HST purposes. ...

CRA declined to comment on whether the supply of memberships or points was a supply of intangible personal property or real property in the absence of being provided with the relevant agreements other than to say that if the supply of points gave the recipient only the right to use real property, the supply would be considered as a supply of real property for GST/HST purposes. ...

CRA responded: For the purpose of determining whether the US business was "substantial" in relation to the Canadian operations in the context of [various] rulings, a number of factors were considered which included, but were not limited to: the relative amount of assets and revenues, number of employees involved in each jurisdiction, and in certain circumstances the relative amount of income and compensation expenses. … [S]ome of the more significant comparative ratios are summarized below: ...

Therefore, the Loyalty Points awarded to customers as a result of consumption of telecommunication services, on special occasions such as birthdays, or upfront based on the expectation of future consumption of telecommunication services can be viewed as a coupon upon redemption; the awarding of the points to customers is considered a taxable supply that does not attract GST/HST where there is no consideration charged to the customers for the supply. ...

18 October 89 Meeting with Quebec Accountants, Q.4 (April 90 Access Letter, ¶1166)-- summary under Subsection 191.1(1) Summary Under Tax Topics- Income Tax Act- Section 191.1- Subsection 191.1(1) Where a shareholder holds identical shares of a corporation some of which are taxable preferred shares and some of which were issued before 1987, and less than all of the shares are redeemed, the shareholder and the corporation may decide which of the shares will be considered to have been redeemed first. ...

The shares or trust units are considered to be acquired when legal ownership of the shares has been transferred and the vendor has entitlement to receive payment. ...