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Assuming that one of the main purposes of the loan may reasonably be considered to be to reduce the income of the individual and to benefit a "designated person" (as defined in subsection 74.5(5) of the Act) in respect of the individual, subsection 74.4(2) of the Act will apply for any taxation year in which the loan is outstanding and the individual is resident in Canada to determine the amount that is deemed to have been received as interest in the year by the individual. ...

However, this issue had been raised some time ago by one of the band and the available information here about intent and past practice was considered before responding to that request. ...

It is your view that the sale of the shares by HOLDCO would be considered as an adventure in the nature of trade and will generate active business income which could be eligible for the small business deduction. ...

Our comments: We agree with you that in the situation described, since there are no specified non-resident shareholders, regardless of the amounts of contributed surplus and paid up capital attributable to A Ltd. no amounts of contributed surplus or paid up capital will be considered in computing the amount described in subparagraph 18(4)(a)(ii) of the Act. ...

However, we have also considered the effect of the two paragraphs in Article 13. ...

Dear Sirs: This is in reply to your letter of July 25, 1989, wherein you requested our opinion on whether an employer provided automobile would be considered to be "available to a taxpayer" for the purposes of subsection 6(2) of the Income Tax Act (the "Act") in the following circumstances: 1. ...

In conclusion, since the dividend excess comes from an appraisal difference of the FMV for V-Day and since the Act covers this type of situation by the application of Part III tax, we do not recommend that subsection 247(1) be considered. ...

For example, if you disposed of your Treasury Bill prior to maturity and received proceeds at the same effective rate of return you would have received had the Treasury Bill been held to maturity, all of the proceeds in excess of your adjusted cost basis would be considered to be interest income. ...

Question 1 We assumed that taxpayers should be considered as clients, although it is not an apt description. ...

If it did, the costs would normally be considered to be eligible capital expenditures. ...