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Construction is not considered "manufacturing or processing" by virtue of subparagraph 125.1(3)(b)(iii). ... " The fact that an activity which if performed at the taxpayers' place of business would be considered "manufacturing or processing" should be of no significance in assessing whether the taxpayers' activities at the construction site are considered manufacturing and processing for purposes of the Act. ... Labour costs for activities considered as construction would obviously not be included in "manufacturing and processing labour". ...

While, in these circumstances, the sub-leasing revenue would be considered from the operation of ships, in any case where the sub-time chartering activity constitutes a separate business the revenue therefrom would not be considered to be from the operation of ships. ... Income from shipbroking will not be considered income from the operation of ships. ... Interpretation Bulletins IT-290, IT-371 and IT-400 outline some of the criteria that should be considered when determining which of a corporation's businesses should be considered its principal business. ...

While, in these circumstances, the sub-leasing revenue would be considered from the operation of ships, in any case where the sub-time chartering activity constitutes a separate business the revenue therefrom would not be considered to be from the operation of ships. ... Income from shipbroking will not be considered income from the operation of ships. ... Interpretation Bulletins IT-290, IT-371 and IT-400 outline some of the criteria that should be considered when determining which of a corporation's businesses should be considered its principal business. ...

Accordingly, it would be considered to be earned in the normal economic mainstream, and thus not considered personal property on a reserve. ... Although this is one factor that must be considered in determining whether such interest is exempt from taxation, other factors must also be considered. ... Because such income may be generated off the reserve or by non-Indians, it would be considered to be earned in the normal economic mainstream and, accordingly, not considered personal property situated on a reserve. ...

As it appears that the transaction in question (i.e. the sale of shares of Parent Co.) has been completed, a request for an advance income tax ruling would not be considered. ... The question to be addressed is whether the building, while under construction, would be considered an asset “used principally in an active business”. ... The issue of whether property was used or held by a corporation in the course of carrying on a business was considered by the Supreme Court in Ensite Limited v. ...

The balance of any foreign taxes would be considered to apply to the non-taxable half of the gain and be deducted from exempt surplus. ... While tax credits are not considered as taxes paid, they should first be considered to apply to the taxes on income to which they relate. For example employment tax credits and investment tax credits for investing in assets to be used in an active business should first be considered to apply to reduce taxes on active business income and only considered to reduce taxes on FAPI to the extent they are used to do so after taxes on active business income are eliminated. ...

The balance of any foreign taxes would be considered to apply to the non-taxable half of the gain and be deducted from exempt surplus. ... While tax credits are not considered as taxes paid, they should first be considered to apply to the taxes on income to which they relate. For example employment tax credits and investment tax credits for investing in assets to be used in an active business should first be considered to apply to reduce taxes on active business income and only considered to reduce taxes on FAPI to the extent they are used to do so after taxes on active business income are eliminated. ...

c) What is considered to be a temporary work assignment and when does a work assignment stop being temporary? ... In fact, he would be considered to be resident there until such time as he could be considered resident elsewhere. ... Questions a) Where is the husband considered to ordinarily reside during the five month work assignment? ...

You are concerned that paragraph 2 of Article 4 (“Article 4(2)”) of the Convention may preclude a Society from being considered a resident of Australia. In our opinion the negotiators of the Convention intended that exempt organizations, such as a Society, be considered resident in the country in which they were organized. Accordingly, we are of the view that Article 4(2) of the Convention would not preclude a Society from being considered resident in Australia for purposes of the Convention. ...

Yes, if the promissory note is considered conditional payment for the shares. 2. No, if the promissory note is considered as absolute payment for the shares. ... Whether or not a promissory note is considered as conditional payment or absolute payment is a question of fact. ...