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Given that a qualifying subsidiary of a qualifying subsidiary of the particular corporation is also a qualifying subsidiary of the particular corporation, C3 (applying this rule iteratively) is considered to be a qualifying subsidiary of Hold Co, as is C4. ...

For voluntary registration, the effective date of registration is usually the date the person's application is considered to be received by the CRA (for example, when an application is mailed, the post-marked date). ...

Applying the contextual modifications that are necessary to give effect to the reference in subsection 15(2.192) to the “specified right” definition in subsection 18(5), where a financial institution lends money on commercial terms to an individual that is a shareholder of a corporation, the corporation provides a security interest in its property to the lender, and such property can only be used in the event of default on the loan as a means of repaying amounts owing by the debtor under the lending agreement, then the security interest would not ordinarily be considered a “specified right”. ...

CRA stated: The CRA’s position has been that where a registered supplier supplies goods on a delivered at destination basis and the terms for the sale of the goods dictate that the supplier must deliver the goods to a destination specified by the recipient, the delivery of the goods will generally be considered to be part of a single supply. ...

This rule would normally apply as the corporations would not be considered to be dealing at arm’s length and the recipient may not be a registrant using the goods exclusively in commercial activity. ...

Wilson noted that although the interest would probably be income from property, as for the dividend income, given that the Rulings Directorate and the courts have indicated a very low threshold for when a corporation has a business, the corporation would likely be considered to have a business. ...

An extra‑curricular activity is generally considered to take place under the authority and responsibility of the school authority if persons employed by or under contract with the school authority, or volunteers reporting to the school authority, supervise and control the activity. 17. ...

Workshops, conferences, retreats and seminars are generally not considered to be courses. ...

For example, image, video, or audio, without accompanying text, will not be considered “written content”; it does not carry on a broadcasting undertaking as defined in subsection 2(1) of the Broadcasting Act; it does not receive an amount from the Aid to Publishers component of the Canada Periodical Fund in the taxation year in which it seeks to claim the credit; and it must meet one of the following conditions in the definition of Canadian newspaper, in subparagraph 19(5)(e)(iii) of the Act, if it is a corporation having share capital: if it is a public corporation, a class of shares of its capital stock is listed on a designated stock exchange in Canada, and the corporation is not controlled by non-Canadian citizens or subjects; or if it is any other type of corporation, at least 75% of shares having full voting rights under all circumstances and, shares having a fair market value in total of at least 75% of the fair market value of all of the issued shares are beneficially owned by Canadian citizens or by public corporations described in (1). special rules apply when the shares are held, or deemed to be held by another corporation (i.e., other than a public corporation a class of shares of its capital stock of which is listed on a designated stock exchange in Canada) or by a partnership in order to determine who shall be deemed to own those shares of the corporation and in what proportion. ...

For the purposes of section 12 of Part III of Schedule V, such spaces are considered to be cafeterias. ...