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Would partnership A be considered to have acquired a specified animal from a person with whom it was not dealing at arm's length? ... Would partnership C be considered to have acquired a specified animal from a person with whom it was not dealing at arm's length? ... Would partnership G be considered to have acquired a specified animal from a person with whom it was not dealing at arms length. ...

Will a passive rental property be considered to be used in the business of a sole proprietor? ... Each of the corporations would be considered to have disposed of their partnership interests at the fair market value thereof. ... Where the transaction is considered to be at arm's length the provisions of subsection 1100(2.2) of the Regulations may be available. ...

Is a video tape considered to be certified for the purpose of the definition of certified production, after Part A or Part 8 of the certification form has been filed and accepted by the M.O.C? ... In other words, even though Part 8 of the form was never completed and the conditions therein not satisfied, the certificate could still legally be considered a valid certificate. ... If an amount invested in an uncompleted and uncertified film or video tape is not eligible to be included in class 10(s), it could be considered capital property of the investor. ...

This case did not specifically address the issue of whether individual assets are considered capital or instead part of an entire operation process. Instead it dealt with the issue and meaning of "structure" and what was considered to be included in Class 3 rather than Class 8. ... As indicated in our August 19, 1985 memo and as indicated above, a part of a larger asset can be considered to be a separate capital property. ...

You indicate that Interpretation Bulletin IT-343R gives guidance as to which foreign entities are considered corporations for the purpose of subdivision i of Division B of Part I of the Income Tax Act (the "Act"). ... KG" and are of the opinion that a KG cannot be considered to be a corporation. ...

Brennan's letter contains the following statement "since XXXX sojourned in Canada for more than 182 days in 1973, he would be considered to be a resident of Canada for the period of time that he resided here in 1973". The last part of this statement should read "he would be considered to be a resident of Canada for all of 1973". ...

Watkins Award (the "Watkins Award") would be considered to be a prescribed prize for purposes of subparagraph 56(1)(n)(i) of the Income Tax Act (the Act) as defined in section 7700 of the Income Tax Regulations (the Regulations). ... Our Comments The word "prize", in the context of the Act, has been considered by the Supreme Court of Canada in The Queen v. ... In view of the forgoing, it is our opinion that the Watkins Award would not be considered to be a prescribed prize as defined in section 7700 of the Regulations. ...

Cash or near cash property is considered to be used principally in the business if its withdrawal would destabilize the business. 3. Cash which is temporarily surplus to the needs of the business and is invested in short-term income producing investments could be considered to be used in the business. 4. Cash or near cash which is surplus to the needs of the business over the long term would not generally be considered to be used in the business. 5. ...

It is our view the portion of the tax paid, which relates to "net income", (shown with an * asterisk above) would be considered as an income or profits tax paid to a government other than Canada. However, when such tax is based on capital, or on a minimum tax liability, it would not be considered as a business-income tax for the purposes of paragraph 126 (7)(a) of the Act. ... When non-refundable taxes are imposed under this legislation which are not considered to be "Income and Profits" taxes from a business carried on by the taxpayer pursuant to paragraph 126(7)(a), they would still be deductible in the computation of taxable income pursuant to section 18 (1)(a) of the Income Tax Act. ...

(iii) Facts as for example (i), except that the 1988 drilling expenses were originally considered to be CEE. ... (iv) Facts as for example (i), except that the 1988 drilling expenses were originally considered to be CEE, and no accumulation is found at the deeper zone, so the well is plugged back to the original reservoir, from which it continues to produce. ... According to an assessing policy, well recompletion costs related to the portion of the well that was drilled in 1993, the portion of the well that had been drilled in 1988 and the level where production was taken prior to the discovery of the new reserves, are considered to be Canadian exploration expense in accordance with 66.1(6)(a)(ii.1)(A). ...