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Notwithstanding that a designation may be made under subsection 104(19) of the Act, it is the Department's view that a corporate beneficiary of a trust would not be considered to own any shares of the payer corporation for purposes of considering whether it is connected under the provisions of paragraph 186(4)(b) of the Act. ...

As a consequence it is our view that the blocked currency would be considered to be property and that paragraph 3501(1)(e.1) would be applicable to the blocked currency donation. ...

We have been unable to find any support for your contention that by issuing a loan to pay off the second mortgage B would be considered as having an implied interest in that particular piece of real estate and would suggest therefore that the assessment of the withholding tax be discontinued unless you have further support for your position. ...

Accordingly, an Indian band council which is considered for purposes of paragraph 149(1)(c) of the Act to be a municipality in Canada would be exempt from tax under part I of the Act in respect of all of its taxable income. ...

We agree with the opinion expressed by the Calgary District office in their letter dated March 29, 1984 (a copy of which you submitted) that the value of a stock option benefit is considered to be income from an office or employment and therefore properly subject to withholding at source by the employer although the requirement to withhold may be waived in circumstances where the withholding would cause undue hardship. ...

Our views in respect of transactions by hypothetical taxpayers should be considered only as an expression of a very general interpretation of the law. ...

In our view trade accounts payable would not normally be considered either a loan or advance or a bond, debenture, note, mortgage, hypothec or similar obligation within the meaning of paragraphs 181.2(3)(c) and (d) but rather would be other indebtedness which may be required to be included in capital pursuant to paragraph 181.2(3)(f). ...

In other words, as stated above the proceeds from the sale of one parcel of land will not be considered to be revenue related to ownership of any other parcel of land. ...

Subparagraph 127.52(1)(i)(ii) allows a deduction in computing adjusted taxable income equal to the "amount that can reasonably be considered to be the amount that he would have deducted" had all calculations been made without any reference to fractions. ...

The possibility that paragraph 12(1)(x) may apply to include a premium in an issuer's income has been considered but no general conclusion has been reached as such a conclusion would be a factual determination. ...