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The real estate listing, which is an integral part of the services provided by a real estate broker cannot, in our view, be considered "merchandise" by any existing legal or dictionary definitions. ...

The portion, if any, of the income earned or realized after 1971 ("safe income") of Opco attributable to the unrealized gain in the common shares of Opco immediately before they were changed to preferred shares would normally be considered to be reflected in the unrealized gain on the Opco preferred shares prior to their redemption. ...

District Office Position Paragraph 13 of IT-218R indicates that the units in a multi-unit residential apartment will be considered to have been converted to inventory at the time when application is made to the relevant authority for approval to change the title to any such building to strata title, provided that the owner proceeds with the sale of the units. ...

Where a limited partnership assigns or transfers its ownership of full recourse promissory notes received form its limited partners in payment for their purchase of the partnership units to another person (e.g. a developer) and the partnership has no further interest in the notes, the notes will generally be considered to be an amount owing by the limited partners to the developer. ...

It is our further view that, in light of the clear intent of the legislation to tax the benefit and the clear intent of the employer to confer a benefit on the employee, the provisions of subsection 245(2) may also be considered in assessing and/or quantifying the benefit under Part I of the Act. ...

To the best of your knowledge, and that of any of the taxpayers, none of the issues involved in this ruling request is: (i) involved in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; and (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... A corporation is also considered to have significant influence over a second corporation if the first corporation has significant influence over a third corporation that has significant influence over the second corporation; (u) "specified financial institution" ("SFI") has the meaning assigned to that term by subsection 248(1) of the Act; (v) "stated capital" and "stated capital account" have the meaning assigned to those terms by section 24 of the BCA; (w) "subsidiary wholly-owned corporation" has the meaning assigned to that term by subsection 248(1) of the Act; (x) "substantial interest" has the meaning assigned to that term by subsection 191(2) of the Act; (y) "taxable Canadian corporation" ("TCC") has the meaning assigned to that term by subsection 89(1) of the Act; and (z) "taxable dividend" has the meaning assigned to that term by subsection 89(1) of the Act. ... For greater certainty, the following principles will also be applied in determining the net FMV of Opco's property for the purposes of the proposed transactions: (a) any tax accounts, such as the balance of any non-capital losses and net capital losses will not be considered property; and (b) liabilities will be determined in accordance with generally accepted accounting principles, except that the amount of deferred income tax will not be considered a liability. 25. ...

A transfer for fair market value consideration is not considered to have taken place for purposes of the Act unless a number of conditions are met. ...

Also, the application of the Dependent Services Article in a particular income tax convention (i.e. the country in which the international organization is located and in which the employee renders his services) would have to be considered. ...

., 90 DTC 6607 (FCA), at page 6612: A considerable body of jurisprudence has developed certain principles applicable in determining whether or not sums of money received by a taxpayer are to be considered as income in the tax period when received or are to be recorded as a liability or in some other way. ...

These positions are based upon recommendations contained in section 3050 of the Handbook (the "Handbook") of the Canadian Institute of Chartered Accountants (the "CICA") which is considered to be the authority for generally accepted accounting principles in Canada. ...