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(c) Can a company with no liabilities be considered insolvent for purposes of subsection 50(1)(b)(iii)? We are of the opinion that a corporation with no liabilities generally cannot be considered to be insolvent. ... The opinions expressed herein are not advance income tax rulings and, in accordance, with paragraph 24 of Information Circular 70-6R, are not considered binding on the Department. ...

Interpretation Bulletin IT-50R outlines our position concerning the date on which a depreciable property is considered to be acquired. ... Where the development of the basic food product still involves the growing process and natural biological changes as opposed to artificially manufactured foods or mere processing, I do not feel that, generally speaking, the activity would be considered by the general public anything other than agricultural in nature and would, therefore, generally be considered as a farming operation". ... In addition, these properties will normally be considered as used in a processing activity for the purposes of the manufacturing and processing profits deduction. ...

Second, as noted in the Northern Residents Deductions Tax Guide, continuity is not considered to be broken by short term absences from the prescribed area such as vacations and temporary work assignments. ... A married student would normally be considered a continuing resident in the place where his spouse and dependants reside. ... Similarly, there may be a situation where a student who does return to the prescribed area in the summer and during school holidays, is considered a permanent resident of the non-prescribed area. 2. ...

Ct.) in which the Exchequer Court considered whether an open-pit gypsum operation was a mine in the context of "income derived from the operation of a mine" for the purpose of the three year tax exemption available at that time. ... The Quarry operation is similar to the sand and gravel operation in the case of Nomad Sand and Gravel Limited in that they are both considered as stone quarries. ... Subsequent activities such as crushing, washing, screening and sorting of the mineral material in order to make the product of the mine or pit marketable are considered to be processing activities. ...

A transaction that takes the form of a lease is usually not considered a sale under provincial law, since the form of a transaction is generally determinative of its nature. Nevertheless, form will be disregarded if it is not considered to reflect the true legal rights of the parties to the agreement. ... In these circumstances, the provisions of subsection 16(1) and paragraph 20(1) of the Act are generally considered applicable to the lender and borrower respectively in the calculation of their income. ...

Advances to other corporations within a corporate group are generally considered to be cash or near cash. ... Cash proceeds received upon the sale of a business property which are to be used for the purchase of another business property will not be considered to be a business property. ... In such as case, the increase in the net value of the business asset would be considered a prohibited acquisition of net assets in contemplation of the intended butterfly. ...

Is the asphalt produced from a fixed plant location considered to be a good sale for the purposes of the manufacturing incentives claimed, in view of the fact that the asphalt is used by the taxpayer in performing its road paving contracts? ... Therefore, as indicated in paragraph 7 of IT-411, where asphalt is manufactured on-site by a portable asphalt plant, this activity is considered to be construction and the plant will qualify as class 10(h) and not as class 29. Where the asphalt is manufactured at the corporation's fixed plant location, this activity will be considered manufacturing and processing. ...

The matter raised has been carefully considered and the conclusion reached is that GST paid on the purchase of a new home is not considered a tax "...imposed on the transfer or registration of title... ...

We hereby replace ruling C set out in the Ruling with the following: Absorbco, as the surviving corporation, will continue and maintain its existing taxation year and will not be considered to have disposed of its assets upon the merger described in paragraph 19 above. We hereby replace ruling F set out in the Ruling with the following: Absorbco, as the surviving corporation, will continue and maintain its existing taxation year and will not be considered to have disposed of its assets upon the merger described in paragraph 20 above. ...

Prior to August 1975, this Department administratively considered Medicare supplements paid to retirees from an employer's general funds as non-taxable payments, although such amounts paid to or in respect of current employees are and always have been considered taxable benefits. ...