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While a tuxedo usually is not considered a costume, it would certainly fit within the definition of "apparel... used for earning rental income" as described in paragraph (k) of Class 12 of the Regulations. ...

A business, the principal purpose of which is to derive income from property (including... rents...) is considered a "specified investment business" unless it employes throughout the year more than five full-time employees. ...

It is our view that a beneficiary of an EPSP in the situation described by you would not be considered to have an interest in the underlying insurance policy. ...

In the situations described above, control would normally be considered to be acquired on closing, when title to the shares passes, unless the purchase and sale agreement provides otherwise. ...

A subsidiary corporation is considered a legal entity, separate and distinct from the parent corporation. ...

In determining the reasonableness of a fee the following should be considered: a) the nature of the services rendered and time expended in performing those services; and b) the fees which would be paid to obtain similar services from other services. ...

Whatever amount up to $100 (10% of $1,000 computed under subparagraph 66(4)(b)(i)) that the taxpayer chooses to claim in 1991 would be the amount deducted for the year and would also be considered as the amount that was deductible in 1991 for purposes of calculating the 1992 claim. ...

XXX The Department's administrative practice with respect to rights of first refusal, in the context of shareholder agreements, is expressed in paragraph 31 of IT-64R2 as follows: "Shareholder agreements commonly referred to as `the right of first refusal' are considered not to confer a right to acquire a share but rather an option to acquire, in certain future circumstances, a right to acquire a share. ...

The deductible amount under this subparagraph is equal to the lesser of: a) the amount of contributions (other than AVC's, prescribed contributions and past service contributions before 1990 while not a contributor (147.2(4)(b))) made by the individual in the year or a previous year in respect of years of service prior to 1990, minus deductions previously claimed in respect of those contributions, and b) $3,500 minus the total of amounts deducted for amount of employee's pension contributions deductible for service after 1989 and for service before 1990 while not a contributor under subparagraphs (147.2(4)(a) and 147.2(4)(b)) of the Income Tax Act. 3) Commencing in 1989, the full amount of instalment payments, including any instalment interest charge paid to the pension plan, is considered to be a pension contribution. ...

We are unable to formulate an opinion as to the income tax consequences of the conversion without first having determined and considered all relevant facts so as to permit us to understand what the commercial substance of the transaction is. ...