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The central management and control of a corporation is usually considered to be exercised by the group that performs the function of a board of directors of the corporation. ... There must be sufficient control exercised from a reserve in order for the organization to be considered to be resident there. ...

Amounts Paid to a Medical Practitioner or Hospital Pursuant to paragraph 118.2(2)(a) of the Act, an amount is considered to qualify as a medical expense of an individual only if it is paid to a medical practitioner, dentist or nurse or a public or licensed private hospital in respect of a medical or dental service. ... In our opinion, a weight-loss program would be considered a medical service when the program is offered to an individual for therapeutic or rehabilitative reasons. ...

It must not be considered a personal or living expense. Items such as housing, clothing, food, and medical bills are considered personal or living expenses. ...

A new location probably would not be considered a replacement property for an old location if the business operations at the two locations are carried on simultaneously, other than for a brief transitional period. ... For example, the Income Tax Rulings and Interpretations Directorate has previously given a general interpretation that the purchase of a 3,000-acre farm would not likely be considered a replacement property for a 200-acre farm. ...

Officials of the 24(1) who are considered factual residents of Canada are subject to Canadian tax on remuneration earned there from (see "1" and "2" above). ... Generally, persons who are considered residents of Canada (whether factual or deemed) are eligible for benefits. ...

Providing the loan meets the conditions outlined in these paragraphs and the property in your example was not principally acquired for the purpose of gaining or producing income therefrom, and this is a question of fact, rental income earned in the circumstances of your example would probably be considered incidental income.  ... Please note that loans made or indebtedness arising in respect of repairs, alterations, renovations or additions made to a dwelling are not considered to qualify for the exception under subparagraph 15(2)(a)(ii) of the Act.  ...

The hedge is considered to be a separate transaction so any gain or loss on the hedge arrangement would not affect the amount of the reduction in ACB of the partnership interest.  ... Where the taxpayer holds his partnership interest as capital property and is not in the business of buying and selling currency futures contracts, the gain or loss on the hedge transaction would ordinarily be considered to be on capital account unless the taxpayer had chosen to report such gains and losses on income account, pursuant to the comments in the first sentence of paragraph 6 of IT-95R.  ...

It is also our view that it is not intended that U.S. citizens, wherever resident, be considered residents of the U.S. for purposes of the Convention and entitled to the benefits thereof. ... Accordingly, a U.S. citizen who would meet the "substantial presence" test in the United States if he were an alien, will be considered "liable to tax" for purposes of paragraph 1 of Article IV of the Convention. ...

Paragraph 31 of Interpretation Bulletin 145R commenting on these restrictions states:      "If a good can be sold in bulk, but is packaged for the convenience of making the sale or because the taxpayer can receive a higher price if the product is placed in packages, it will generally be considered to be a finished good before packaging takes place.  However, a homogenous product which in the usual case must be broken from bulk and packaged before it is capable of sale is generally not considered to be a finished good until after the time, it is packaged".  ...

This issue was considered by the Federal Court-Trial Division in The Queen v. ... We agree with your view that an Indian working at a school located on "surrendered land" would not qualify for the remission of tax as he would not be considered to be performing duties on a reserve. ...