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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. ...

A post-secondary college or post-secondary technical institute may have certain reasonable admission standards, such as educational prerequisites, and still be considered to be providing educational services to the general public. ...

Where the essential character of the service for which an incidental seller earns its fees is the sale of insurance on behalf of the insurer to the customer, it will generally be considered an exempt supply of a financial service. ...

CRA essentially confirmed this interpretation, stating: While a change in use of 10% or more is normally considered to be a significant change in use (i.e. because section 197 considers any change of less than 10% to be insignificant), section 141 nevertheless considers that the entire use of the capital property is not commercial activities. ...

7 April 2022 CBA Roundtable, Q.3-- summary under Real Property Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Real Property two annexation tests for determining whether personal property has become a fixture CRA confirmed that since appliances and common area furniture and equipment that are acquired in connection with the construction of, say, a residential complex such as an apartment building and which do not become fixtures, will be considered to have been acquired for the purpose of the intended exempt rental of the completed units, so that no input tax credits will be available. ...

In this context, the CRA would consider the construction of an addition to a multiple unit residential complex (MURC) that expands the building envelope of the existing MURC to be the construction of one or more “residential units” as defined in subsection 123(1) of the ETA. b) An internal reconfiguration of units within a MURC which results in new residential units but which does not expand the building envelope is not considered to be the construction of an addition to a MURC. c) Where there is a construction of an addition to a MURC requiring self-assessment under subsection 191(4) of the ETA, the fair market value of the addition under paragraph 191(4)(e) of the ETA would not include the land if the addition to the MURC is constructed on land that is contiguous to the existing building and that was reasonably necessary for the use and enjoyment of the existing building as a place of residence for individuals. ...