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It would not be considered reasonable for a shareholder-employee or employee who provides services of relatively minor value or which have little or no impact on the amount of the corporation's profits to receive a large salary or bonus. ...

Department's Position A class of shares would not be considered to be shares that are not shares of a "specified class" by reason only of the fact that dividends payable thereon were not cumulative. ...

Whether or not two or more persons or other entities are at arms length with each other is a question of fact which may only be determined from a review of those facts in the light of the criteria generally considered in making such an ascertainment including the degree of control of the entities in question by a third party. ...

Notwithstanding the fact that no portion of the payments made by the Guarantor may be considered as interest insofar as it is concerned, the Guarantor would nevertheless be making payments to the Bank on the Guarantee “on account or in lieu of payment of or in satisfaction of interest” owing by the Parent to the Bank. 3. ...

If the fair market value of the property received in payment of the debt is equal to $1,000 U.S. a capital gain of 845 Canadian dollars would be considered to have been realized by virtue of a fluctuation in the currency and would also be deemed to be nil pursuant to paragraph 95(2)(g) of the Act. ...

If part of the forgiveness is considered to be for the disposition of the right to have the lenders finance the future cost and such a right is capital property it would be an excluded property as it was used or held in an active business. ...

The situations at hand are similar to those considered in Southport Corporation v. ...

Will a Canadian beneficiary be considered to have received a taxable benefit for the purpose of subsection 105(l). ...

Specifically, you are enquiring whether or not the corporation would continue to be considered an SPC by the Department if the property is rented to non-shareholders. ...

If xxxxx is considered to be a resident of the United States for the purposes of the Canada-U.S. ...