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You have asked for our comments regarding whether the amounts paid to individuals from developing countries in order to come to Canada to attend school full-time (usually for a period of one to three years) would be considered taxable income under paragraphs 56(1)(n) or 56(1)(o) of the Income Tax Act (the Act). ... As was the case in the previous review, there is nothing in the material submitted to us to suggest that the work (study) undertaken by these trainees would constitute "research" in the sense explained in Interpretation Bulletin IT-75R3 or that the amounts so received should be considered "research grants" pursuant to paragraph 56(1)(o) of the Act. ...

Should a particular amount be required to be included in the computation of income by virtue of either of the above provisions or paragraph 12(1)(a), such an amount would fall within the exception contained in subparagraph 12(1)(x)(v) and would be considered to have been included in income otherwise than by virtue of paragraph 12(1)(x). ... Otherwise, none of the remaining payments would be considered to be in respect of the cost of capital or depreciable property acquired by the taxpayer. ...

B is used to provide the 24-hour care and is considered to be the principal place of residence of the handicapped adults.? ... C provides some part-time care in her principal residence, but her residence is not considered the principal place of residence of the handicapped adults.? ...

You should note that a wage loss replacement plan (WLRP) is not considered to be an EBP according to the definition of EBP in subsection 248(1). Rather, a WLRP is considered a plan to which paragraph 6(1)(f) applies. ...

Although the amounts of the prescribed limits in Regulation 7306 are generally acceptable as reasonable, those limits are not considered to define the term "reasonable". ... In the context of motor vehicle allowances described in subparagraphs 6(1)(b)(v), (vi) or (vii.1) of the Act, there are additional reasonableness criteria that must be met before such an allowance can be considered reasonable. ...

Where a policy is silent with respect to the addition of such a rider the amending of the policy, if considered by the Department to be a material change, could be considered a disposition of the existing policy and the acquisition of a new policy. ...

Where a policy is silent with respect to the addition of such a rider the amending of the policy, if considered by the Department to be a material change, could be considered a disposition of the existing policy and the acquisition of a new policy. ...

An amount determined in some other manner- such as by reference to the percentage gain in a stock exchange index over a set time period- is not considered to be referable to a principal sum. ... In determining the relevant commercial rates, the credit rating of the borrower will be one of the factors to be considered. ...

A trust is generally considered to reside where the trustee or other legal representative who manages or controls the trust assets resides. ... In these situations the residence of this other person may be considered to be the determining factor of the residence of the trust regardless of any contrary provisions in the trust agreement. ...

In such a situation, he is considered to be an employee of that Canadian company. ... A are not considered to be employees of the Canadian company. Where a parent company (i.e. ...