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Repayment by set-off or application of dividends or bonus 1.82 A loan can be considered to have been repaid by way of set-off against a receivable of the borrower. ... Bona fide commercial loan exception 1.85 A repayment may also be considered to have been made as part of a series of loans or other transactions and repayments where the proceeds of a new loan are used to repay an existing shareholder loan. However, such a repayment will not be considered part of a series of loans or other transactions and repayments if it can be shown that the new loan was from an independent source, was received for a genuine business purpose, and was not received for the purpose of repaying the existing shareholder loan amount. ...

IT-441 dated November 29, 1979 "Capital Cost Allowance- Certified Feature Productions and Certified Short Productions"-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "A disposition of the film or tape will be considered to take place where the investor grants to a person or persons the right to distribute or otherwise exploit the film or tape in markets representing most or all of the exploitable value of the film or tape for a fixed amount of consideration or for a guaranteed minimum consideration which can reasonably be considered to be its fair market value. ...

This is not considered to result in double taxation as a benefit is only considered to arise where it cannot be demonstrated that membership is principally for the employer's advantage. ...

However, if a person purchases bonds on the secondary market (that is, from a person other than the issuer of the bonds or an agent thereof), the person is not considered to have lent money to the bond issuer. Cash generates bad interest Example 3. … [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c). ...

However, if the Canadian corporation's borrowing of funds or the giving of the guarantee can be considered to be part of the series of transactions which results in a tax benefit and may reasonably be considered to have been undertaken or arranged primarily to obtain a tax benefit, the transaction nonetheless may be subject to s. 245(2). ...

23 October 2000 Interpretation 11640-1-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 7 The Canadian operator of an internet auction site would be considered, with respect to non-resident vendors, to be arranging for, procuring or soliciting orders for supplies made by them. The payment of an annual fee by vendors for the right to list items on the auction site would be considered to be consideration for a supply to them of a right and would not be eligible for zero-rating and would be deemed by s. 142(1)(c)(i) to be a supply made in Canada. ...

("This situation may be considered abusive because the Canadian taxpayer has turned an otherwise taxable receipt of monies into a non-taxable amount.") Conversely, when a Canadian parent company requests and receive a decrease in the transfer price of sales to a non-resident subsidiary without repatriation, this is not considered abusive, because s. 15(1) would apply and offset the downward adjustment. ...

GST/HST Memorandum 28-3 [28.3] Passenger Transportation Services July 2019-- summary under Section 4.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part VI- Section 4.1 Assimilation to same place of supply of cancellation of ticket (para. 70) Example 18 A supply of a passenger transportation service from Gander, Newfoundland and Labrador to Toronto, Ontario would be considered to be made in Newfoundland and Labrador. A supply of a service of cancelling the ticket for that trip would therefore also be considered to be made in Newfoundland and Labrador and subject to the HST at a rate of 15%. ...

In other words, in order for a person (or a group of persons) to be considered to hold qualifying voting control of a corporation, 90% or more of shareholder votes in respect of all corporate matters must be held and controlled by the person (or by the group of persons) with limited exceptions. Only where a particular person (or a particular group of persons) has a high degree of both ownership and control of the corporation will the person (or the group of persons) and the corporation be considered to be closely related for GST/HST purposes. ...

" 31 March 2003-- summary under Related Business Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(1)- Related Business Although most fundraising activities are business activities, a fundraising event generally will not be considered to "recur with such regularity and frequency that it amounts to carrying on a business" (para. 12). 17. ... A business will be considered to be linked to the charity's purposes where the quality of services delivered to charitable programs are improved (e.g., hospital parking lots, and cafeterias, and museum book shops) it is an off-shoot of a charitable program (e.g., the sale by a church of recordings of its Christmas concert) it utilizes excess capacity (e.g., university rentals in the summer months) it sells products which promote the charity (e.g., products with the charity's name or logo) ...