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Reasons: Cared-for individuals do not reside in part of facility that is considered the caregivers principal place of residence. ... That is, the cared-for individuals would not be considered to reside in the caregivers' principal place of residence and neither is the caregivers' principal place of residence considered to be maintained for use as the residence of the cared-for individuals. ... The facility provided by the Society cannot be considered the principal place of residence of the caregivers. ...

In our view an acquisition could be considered to be in contemplation of a Purchase Butterfly, even though the particular assets to be transferred or the identity of the purchaser had not been determined at the time of the acquisitions. (2) We agree that acquisitions made in the ordinary course of business would not be considered to be in contemplation of XXX Purchase Butterfly. ... We disagree with your suggestion that an acquisition of an asset that is not itself transferred on a Purchase Butterfly could not be considered to be made in contemplation of such Purchase Butterfly. For example, if an asset were acquired to enable XXX to transfer another asset on a Purchase Butterfly, the acquisition could be considered to have been made in contemplation of the Purchase Butterfly. (4) We disagree with your suggestion that an acquisition that does not achieve a material tax benefit cannot be considered to have been made in contemplation of a Purchase Butterfly. ...

What types of equipment are considered to be qualified construction equipment.? ... If the concrete mixers and stone slinger are considered to be qualified construction equipment by the judge, will that property and the related labour costs of the drivers also be considered to be manufacturing and processing capital and labour for the purpose of section 5202 of the Regulations. ... Consequently, the activity of unloading the concrete from the concrete mixer would be considered the delivery of finished goods. 8. ...

(ii) The student is not considered to satisfy the 13 week requirement set out in paragraph 118.5(1)(b) of the Act. Similarly, the student is not considered to satisfy the 13 week requirement in the definition of "designated institution". 960221 XXXXXXXXXX M. ... If the requirement is considered to have been satisfied by the educational institution and a student is otherwise considered to qualify for the education tax credit, a certificate, which a student is required to file for income tax purposes, should be issued which documents the student's entitlement to the credit. ...

(a) If Non-Res and Can-Res A are acting in concert to control both Non-Resco and Holdco, the latter companies would be considered to be controlled by the same group of persons with the result that they would be related to each other pursuant to subparagraph 251(2)(c)(i) of the Act. As Opco is owned 30.91% by Non-Resco and 49.35% by Holdco, Opco would, therefore, be considered to be controlled by a related group of persons. ... (b) Provided that Non-Res and Can-Res A are not acting in concert and subsection 256(5.1) of the Act does not apply to result in both Non-Resco and Holdco being considered to be controlled directly or indirectly in any manner whatever by either Non-Res, Can Res A or Non-Res and Can-Res A as a group, and provided also that subsection 256(5.1) of the Act does not apply to result in Opco being considered to be controlled directly or indirectly in any manner whatever by Non-Resco, it is our view that Non-Resco and Opco would not be considered to be related to each other under the Act. ...

If the partnership is considered not to cease to exist upon the death of its partner by the operation of the relevant provincial law, whether the partnership agreement is written or verbal, then for income tax purposes, the partnership is considered not to cease to exist. If a partnership is considered not to cease to exist upon death of a partner of the partnership, the deceased partner is considered to have a right or thing with respect to the income accrued from the end of the last fiscal period of the partnership to the date of death. ... The income accrued and allocated is considered as an allocation of income under subsection 96(1) and not 96(1.1) of the Act. ...

The first issue which needs to be considered is whether the parent is wholly or partially dependent upon the child for support. ... While a hospitalized spouse would not normally be considered to have changed residences solely by reason a hospital stay (and thus no longer be considered to reside with the other spouse), the same may not be true for parents supported by their adult children. ... For example, a hospitalized parent would not be considered to reside with the supporting child if the parent did not reside with the child prior to the hospitalization. ...

(a) If Non-Res and Can-Res A are acting in concert to control both Non-Resco and Holdco, the latter companies would be considered to be controlled by the same group of persons with the result that they would be related to each other pursuant to subparagraph 251(2)(c)(i) of the Act. As Opco is owned 30.91% by Non-Resco and 49.35% by Holdco, Opco would, therefore, be considered to be controlled by a related group of persons. ... (b) Provided that Non-Res and Can-Res A are not acting in concert and subsection 256(5.1) of the Act does not apply to result in both Non-Resco and Holdco being considered to be controlled directly or indirectly in any manner whatever by either Non-Res, Can-Res A or Non-Res and Can-Res A as a group, and provided also that subsection 256(5.1) of the Act does not apply to result in Opco being considered to be controlled directly or indirectly in any manner whatever by Non-Resco, it is our view that Non-Resco and Opco would not be considered to be related to each other under the Act. ...

What types of equipment are considered to be qualified construction equipment? ... If the concrete mixers and stone slinger are considered to be qualified construction equipment by the Judge, will that property and the related labour costs of the drivers also be considered to be manufacturing and processing capital and labour for the purpose of section 5202 of the Regulations. ... Consequently, the activity of unloading the concrete from the concrete mixer would be considered the delivery of finished goods. 8. ...

In our view an acquisition could be considered to be in contemplation of a Purchase Butterfly, even though the particular assets to be transferred or the identity of the purchaser had not been determined at the time of the acquisitions. (2) We agree that acquisitions made in the ordinary course of business would not be considered to be in contemplation of a Purchase Butterfly. ... We disagree with your suggestion that an acquisition of an asset that is not itself transferred on a Purchase Butterfly could not be considered to be made in contemplation of such Purchase Butterfly. For example, if an asset were acquired to enable 24(1) to transfer another asset on a Purchase Butterfly, the acquisition could be considered to have been made in contemplation of the Purchase Butterfly. (4) We disagree with your suggestion that an acquisition that does not achieve a material tax benefit cannot be considered to have been made in contemplation of a Purchase Butterfly. ...