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In such circumstances the departing spouse would not be considered to have severed his residential ties with Canada. ... " Paragraph 8 "If married individual leaves Canada, but his spouse or dependants remain in Canada, the individual will generally be considered to remain a resident of Canada during his absence. ... In such a situation the resident spouse could, for the purpose of computing his eligibility for the CTC, be considered to be residing with his non-resident spouse. ...

Is an employee considered to have established a self- contained domestic establishment (SCDE) if he can only do so by means of the employer-provided housing? If the answer to the first question is that a place cannot be considered remote because the employee could establish a SCDE by means of an employer-provided dwelling, would the place then be considered remote for a single employee who does not qualify for employer- provided housing but is placed in a bunkhouse instead? ... We are unable to provide a checklist of services required that would be considered a minimum level of services. ...

Is an employee considered to have established a self-contained domestic establishment (SCDE) if he can only do so by means of the employer-provided housing? If the answer to the first question is that a place cannot be considered remote because the employee could establish a SCDE by means of an employer-provided dwelling, would the place then be considered remote for a single employee who does not qualify for employer-provided housing but is placed in a bunkhouse instead? ... We are unable to provide a checklist of services required that would be considered a minimum level of services. ...

Will Canco or the lender be considered to have received a taxable benefit from the parent? ... DEPARTMENT'S POSITION Neither Canco nor the lender would be considered to have received a benefit from the parent. ... However, if Canco's borrowing of funds or the giving of a guarantee by the parent can be considered part of a series of transactions, which series, would result in a tax benefit and may reasonably be considered to have been undertaken or arranged primarily to obtain the tax benefit, the transaction may nevertheless be subject to subsection 245(2) of the Act. ...

For these purposes, current liabilities of a corporation are not considered to relate to any particular asset of the corporation. Generally, a particular liability may be considered to relate to a particular asset if the liability is specifically secured by that asset, regardless of the direct use of the proceeds of the borrowing or of the transaction or event giving rise to the particular liability. For example, a loan secured by a mortgage of real property would generally be considered to relate to that property regardless of the direct use of the proceeds of the loan. ...

The utility poles would in our view be considered separate assets or properties which together with the conductors and lines comprise the electrical line system. ... It would be considered an acquisition of a new asset with a useful life of 25-30 years. In our view the comments in paragraph 4 of IT-128R do not support your position that the pole replacement costs could be considered current expenditures. ...

Each participant of a joint venture is considered to be conducting its own business so that it receives each income and incurs each cost to the extent of its participation in the joint venture. ... XXX It is our view that where a joint venture would be considered to be carrying on business in Canada for the purposes of section 253 of the Act if it was a non-resident person, any non-resident member of such a joint venture will also be considered to be carrying on that business in Canada. ... In addition, if a joint venture would be considered to have a permanent establishment in Canada for the purposes of an income tax convention that Canada has with another country, it if were a resident of a contracting state for the purposes of that convention, any member of such a joint venture who is resident in that country will generally be considered to have a permanent establishment in Canada. ...

It is our view that where cash is temporarily surplus to the needs of a business and is invested in short-term income-producing investments, those investments may be considered to be used in the business. On the other hand, where substantial amounts of cash and deposits- in excess of that required for use in the business, are retained in the corporation on a permanent basis, they would not be considered to be funds used in the business. Such funds would be considered to be permanently set aside for investment for uses other than in an active business. ...

Whether the re-negotiated note would be considered to be accepted as "conditional payment" rather than as "absolute payment" is such a matter. ... The extension of the note could occur before the original due date and before the end of the vendor's taxation year for which the reserve is being considered. ... " Thus, it would appear, unless there is evidence to the contrary, that the re-negotiated note in your fact situation may be considered to be accepted as conditional payment and not as absolute payment. ...

The utility poles would in our view be considered separate assets or  properties which together with the conductors and lines comprise the electrical line system.  ... It would be considered an acquisition of a new asset with a useful life of 25-30 years. In our view the comments in paragraph 4 of IT-128R do not support your position that the pole replacement costs could be considered current expenditures.  ...