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Activities beyond this stage (bitumen upgrading and synthetic crude oil production activities) should not be considered as ore processing activities but as a manufacturing and processing activity. ...

Therefore, the $5,000 special remuneration received by the U.K. teacher is considered a payment by the Canadian teacher whether he pays it directly to the U.K. teacher himself or indirectly via his employer in Canada. ...

In applying the provisions of subsection 87(9), it is this test of "control" that must first be considered". ...

The procedure in constructing a table of premium rates for practical use is first to calculate the net premiums and then to add to these the amounts considered necessary to cover expenses and contingencies and, in the case of stock companies, profit. ...

In addition, all of the deemed dividends could not be considered to have been paid from "income earned or realized" as Holdco would not have any "income earned or realized" prior to the commencement of the series of transactions or events for purposes of subsection 55(2) of the Act. ...

E) Second last sentence: A typographical error has deleted the name of the expense which is not considered an operating cost for the purpose of determining the benefit. ...

Our intention was simply to limit the allowable load for administration expenses to an amount which is considered reasonable in the circumstances. ...

Owen J. agreed that the undertaking of unanimity at director's meetings which he considered was reguired by clause 11 might be contrary to public order but that it was not necessary to decide this since the clause was severable from the other provisions of the agreement to which he gave full effect. ...

To the best of your knowledge and that of the taxpayers involved in this ruling, none of the issues contained in this ruling is being considered by any office of Revenue Canada in connection with an income tax return previously filed and none of the issues contained herein is the subject of a notice of objection or is under appeal. ... XXXXXXXXXX 9.On schedules forming part of the corporate income tax return filed for its taxation year ended XXXXXXXXXX reflected the following tax account balances (determined after making any claims for that year and which have arisen as a result of the ownership of XXXXXXXXXX: Investment tax credit $XXXXXXXXXX Scientific research and experimental development expenditures $XXXXXXXXXX Undepreciated capital cost $XXXXXXXXXX Canadian exploration expense $XXXXXXXXXX Non-capital losses $XXXXXXXXXX Net capital losses $XXXXXXXXXX In addition, XXXXXXXXXX has approximately $XXXXXXXXXX of costs incurred in respect of XXXXXXXXXX which are precluded, pursuant to subsection 13(26) of the Act, from being included in its undepreciated capital cost until the relevant property is considered to become "available for use" by it. ...

We understand that to the best of your knowledge, and that of the taxpayers involved, none of the matters considered in this ruling request are: (a) in an earlier return of the taxpayers or related persons; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayers or related persons; (c) under objection by the taxpayers or related persons; (d) before the courts; or (e) the subject of a ruling previously issued by this Directorate to the taxpayers or related persons. ...