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Accordingly, where a taxpayer incurred an allowable business investment loss and an ordinary non-capital loss in Year 1, had income equal to the allowable business investment loss in Year 2, and in Year 3 there was an acquisition of control resulting in the application of s. 111(5), the taxpayer could choose to have the allowable business investment loss considered to have been applied in Year 2. ...

For example, this requirement generally would not be satisfied where the loan is to be repaid once shares achieve a certain fair market value. 1.70 When trade debts are not paid according to the creditor's normal payment terms but they are settled within 12 months of being incurred, bona fide arrangements are considered to have been made at the time the debt arose for purposes of S. 15(2.3). ...

Furthermore, the activities of the MGA could be considered to be also excluded on the basis that they are predominantly preparatory activities. ...

As a result, such a corporation would not be considered as a participant and thus, an operator, of the joint venture for purposes of the section 273 election. ...

As a result, the co-venturer is still considered to have made these supplies. ...

A specific expense is net, after all applicable credits or refunds have been deducted, and is without any mark-up or profit element to the non-resident. 9....a service performed by a non-resident would not be considered beneficial to the payer if it was a duplication of services already provided by the payer's own personnel. 10....Where an amount paid or credited to a non-resident is based on an allocation or distribution of certain charges or costs among various departments, branches or subsidiary corporations (including the Canadian payer), it is important not only that the expenses themselves are reasonable but that the method or basis of allocation or distribution is appropriate to the Canadian payer and reasonable in the circumstances. ...

IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) 27 Repayments are considered to apply first to the oldest loan or debt outstanding ("first-in, first-out basis") unless the facts clearly indicate otherwise. 28....It is a question of fact whether or not a repayment of a loan is part of a series of loans or other transactions and repayments. ...

If this is the case, the Corporation as the supplier of [Product A] would be considered to have made taxable supplies of [Product A] and therefore would have an obligation to charge, collect and remit GST/HST in respect of those supplies. ...

In the case of shared rooms, the above factors and any other relevant factors should be considered in determining whether individuals are given possession of a shared room or suite. ...

GST/HST Info Sheet GI-170 "Charter Flights Supplied to Third-Party Charterers"May 2015-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Single v. multiple supply A ferry flight is generally considered to be an input to a passenger transportation service.... ...