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The $4,000 loss that Amanda incurred during the year is not considered a "withdrawal". ... After the holder's death, the deposit or annuity contract is considered to be a separate contract and is no longer considered as a TFSA. ... The amount paid to Fred, as the surviving common-law partner, is considered a survivor payment. ...

Excessive interest and financing expenses limitation rules Note 1 Interest and financing expenses of a taxpayer for a particular taxation year means the amount determined by the formula A- B where A is the total of all amounts (other than an amount that is included in exempt interest and financing expenses), each of which is (a) an amount that (i) is paid in, or payable in or in respect of, a year as, on account of, in lieu of payment of or in satisfaction of, interest (other than excluded interest for the particular year or an amount that is deemed to be interest under subsection 137(4.1)), (ii) would, in the absence of this section, be deductible (other than under a provision referred to in subparagraph (c)(i)) by the taxpayer in computing its income for the particular year, and (iii) is not described in any other paragraph in this definition, (b) an amount that, in the absence of this section and on the assumption that it is not deductible under another provision of this Act (other than any of the provisions referred to in subparagraph (c)(i)), would be deductible in computing the taxpayer’s income for the particular year under any of subparagraphs 20(1)(e)(ii) to (ii.2) and paragraphs 20(1)(e.1) to (f), (c) the portion of an amount, if (i) the amount, in the absence of this section, would be deductible in computing the taxpayer’s income for the particular year and is claimed by the taxpayer under paragraph 20(1)(a) or subsection 66(4), 66.1(2) or (3), 66.2(2), 66.21(4), 66.4(2) or 66.7(1), (2), (2.3), (3), (4) or (5), and (ii) the portion can reasonably be considered to be attributable to an amount paid or payable on or after February 4, 2022 that either (A) is described in subparagraph (a)(i), or (B) would otherwise have been deductible in a taxation year under a provision referred to in paragraph (b), but for the application of another provision of this Act, (d) the portion of an amount that would, in the absence of this section, be deductible in computing the taxpayer’s income for the particular year under subsection 20(16), to the extent that the portion can reasonably be considered to be described in subparagraph (c)(ii), (e) an amount that is paid or payable by the taxpayer in a year or that is a loss or a capital loss of the taxpayer for a year, as the case may be, under or as a result of an agreement or arrangement, if (i) the amount would, in the absence of this section (A) be deductible (other than under subparagraph 20(1)(e)(i)) in computing the taxpayer’s income for the particular year, or (B) in the case of a capital loss, reduce the amount determined under paragraph 3(b) in respect of the taxpayer or be deductible in computing the taxpayer’s taxable income for the particular year (except to the extent it has already been included under this paragraph for a previous year), (ii) the agreement or arrangement is entered into as or in relation to a borrowing or other financing that the taxpayer or a person or partnership that does not deal at arm’s length with the taxpayer enters into, whether currently or in the future, and absolutely or contingently, and (iii) the amount can reasonably be considered to increase (or be part of) the cost of funding with respect to the borrowing or other financing (including as a result of any hedge of the cost of funding or of the borrowing or other financing) of the taxpayer or a person or partnership that does not deal at arm’s length with the taxpayer; (f) a particular amount that (i) is in respect of an agreement or arrangement that gives rise to, or can reasonably be expected to give rise to, an amount that (A) is included in computing a taxpayer’s interest and financing expenses for a taxation year under paragraph (e), or (B) reduces the taxpayer’s interest and financing expenses for a taxation year under the description of B, (ii) would, in the absence of this section, be deductible by the taxpayer in computing its income for the particular year, (iii) is not deductible under any of the provisions listed in paragraph (b), and (iv) is an expense or fee payable under the agreement or arrangement or an expense that is incurred in contemplation of, in the course of entering into or in relation to, the agreement or arrangement, (g) a lease financing amount (other than in respect of an excluded lease for the particular year) that (i) would, in the absence of this section, be deductible by the taxpayer in computing its income for the particular year, and (ii) is not excluded interest for the particular year, (h) in respect of the income or loss of a partnership, for a fiscal period that ends in the particular year, from any source or from sources in a particular place, an amount determined by the formula C × D − E − F where C is the total of all amounts, each of which is an amount that (i) is deductible by the partnership in computing its income or loss from the source, or the source in a particular place, for a fiscal period, and that would be described in any of paragraphs (a) to (g) if the references to the taxpayer were read as references to the partnership, or (ii) would be included under paragraph (j) in determining the interest and financing expenses of the partnership for the purposes of determining its income or loss from the source, or the source in a particular place, for the fiscal period, if the partnership were a taxpayer for the purposes of this section, D is the taxpayer’s specified proportion, if the references in the definition specified proportion in subsection 248(1) to “total income or loss” were read as “income or loss from the source, or the source in a particular place”, E is the amount, if any, included in computing the taxpayer’s income under paragraph 12(1)(l.1) in respect of the amount referred to in the description of C, and F is the portion of an amount determined for C that can reasonably be considered to not be deductible in computing the taxpayer’s income for the particular year, and to not be included in computing the taxpayer’s non-capital loss for the particular year, because of subsection 96(2.1), (i) the portion of an amount that, in the absence of this section, would be deductible in computing the taxpayer’s taxable income for the particular year and is claimed by the taxpayer under paragraph 111(1)(e) in respect of a partnership of which the taxpayer is a member that can reasonably be considered to be attributable to an amount referred to in the description of F in paragraph (h) in respect of a fiscal period of the partnership ending in another taxation year of the taxpayer, or (j) in respect of a corporation that is a controlled foreign affiliate of the taxpayer at the end of an affiliate taxation year ending in the particular year, an amount determined by the formula G × H where G is the affiliate’s relevant affiliate interest and financing expenses for the affiliate taxation year, and H is the taxpayer’s specified participating percentage in respect of the affiliate for the affiliate taxation year; and B is the total of all amounts, each of which is (a) an amount received or receivable (other than as a dividend or in respect of exempt interest and financing expenses) by the taxpayer in a year, or a gain of the taxpayer for a year, as the case may be, under or as a result of an agreement or arrangement to the extent that (i) the amount is included in computing the taxpayer’s income for the particular year, (ii) the agreement or arrangement is entered into (A) as a borrowing or other financing of the taxpayer or of a person or partnership that does not deal at arm’s length with the taxpayer, or (B) in relation to a borrowing or other financing of the taxpayer or of a person or partnership that does not deal at arm’s length with the taxpayer to hedge the cost of funding or the borrowing or other financing, (iii) the amount can reasonably be considered to reduce the cost of funding with respect to the borrowing or other financing of the taxpayer or a person or partnership that does not deal at arm’s length with the taxpayer, and (iv) the amount cannot reasonably be considered to be excluded, reduced, offset or otherwise effectively sheltered from tax under this Part because (A) an amount is deductible under any of subsections 20(11) to (12.1) and 126(1) and (2), and (B) an amount is deductible in respect of income or profits tax paid to a country other than Canada that (I) can reasonably be considered to have been paid in respect of the amount, and (II) is not a tax substantially similar to tax under subsection 212(1), or (b) in respect of the income or loss of a partnership, for a fiscal period that ends in the particular year, from any source or from sources in a particular place, an amount determined by the formula I × J where I is an amount that would be described in paragraph (a) if (i) the references to the taxpayer in that paragraph were read as references to the partnership, and (ii) the reference in subparagraph (a)(i) to “the taxpayer’s income for the particular year” were read as “the partnership’s income or loss from the source, or the source in a particular place, for a fiscal period”, and J is the taxpayer’s specified proportion, if the references in the definition specified proportion in subsection 248(1) to “total income or loss” were read as “income or loss from the source, or the source in a particular place”. ... (entité exclue) Note 7 Tax-indifferent means a person or partnership that is (a) a person exempt from tax under section 149; (b) a non-resident person; (c) a partnership more than 50% of the fair market value of all interests in which can reasonably be considered to be held, directly or indirectly through one or more trusts or partnerships, by any combination of persons described in paragraph (a) or (b); or (d) a trust resident in Canada if more than 50% of the fair market value of all interests as beneficiaries under the trust can reasonably be considered to be held, directly or indirectly through one or more trusts or partnerships, by any combination of persons described in paragraph (a) or (b).‍ ... (entité du groupe d’institutions financières) Note 9 Exempt interest and financing expenses of a taxpayer for a taxation year means the total of all amounts, each of which would, if the Description of A in the definition interest and financing expenses were read without reference to “exempt interest and financing expenses”, be included in interest and financing expenses of the taxpayer for that year, and that is incurred in respect of a borrowing or other financing (referred to in this definition as the “borrowing”), if (a) the taxpayer or a partnership of which the taxpayer is a member entered into an agreement with a public sector authority to design, build and finance — or to design, build, finance, maintain and operate — property that the public sector authority, or another public sector authority, owns or has a leasehold interest in or right to acquire; (b) the borrowing was entered into in respect of the agreement; (c) it can reasonably be considered that all or substantially all of the amount is directly or indirectly borne by a public sector authority referred to in paragraph (a); and (d) the amount was paid or payable to (i) a person that deals at arm’s length with the taxpayer or the partnership of which the taxpayer is a member, or (ii) a particular person that does not deal at arm’s length with the taxpayer or the partnership of which the taxpayer is a member if it may reasonably be considered that all or substantially all of the amount paid or payable to the particular person was paid or payable by the particular person to one or more persons that deal at arm’s length with the taxpayer or the partnership of which the taxpayer is a member.‍ ...

A reasonable estimate is considered to be the amount an employee would have had to pay in an arm's length transaction for the use of comparable transportation. ... Although other methods of calculating the value of your employee's taxable motor vehicle benefit are acceptable, the CRA generally accepts that the employment benefit arising from the employee's personal use of the vehicle will be considered reasonable if it is calculated using the rates shown in Reasonable per-kilometre allowance. ... For examples of situations where transportation to and from home is considered a taxable benefit, go to Examples – Transportation to and from home. ...

. ¶1.6 (formerly included in ¶2 of IT-427R) has been revised to expand on what is considered to be livestock and to provide a reference to Sniderman v The M.N.R., 89 DTC 323 (TCC). ¶1.7 has been added to discuss a food source. ¶1.8 has been added to discuss raising poultry. ¶1.9 and ¶1.10 (formerly included in ¶6 of IT-322R) have been expanded to discuss fish and shellfish raising which may be considered farming. ¶1.13 (formerly included in ¶6 of IT-322R and ¶25 and ¶26 of IT-268R4) has been expanded to discuss more activities excluded from the definition of farming. ¶1.14 (formerly included in ¶10 of IT-433R) has been expanded to include examples of fishing activities. ¶1.15 has been added to explain that farming generally excludes manufacturing and processing. ¶1.16 has been added to discuss the processing of agricultural product and provides some examples. ¶1.17 (formerly included in ¶1 of IT-433R) has been expanded to mention the election to use the cash method to compute income from a farming business. ¶1.19 (formerly included in ¶13 of IT-349R3) has been expanded to include examples of general management and control of a farming operation. ¶1.20 and 1.21 have been added to discuss two Supreme Court of Canada cases (Stewart and Walls). It also describes how a particular operation must be carried out in a sufficiently commercial manner to be considered a business. ...

Some of these objects are too broad and vague to allow for registration, and others cannot be considered charitable at law. ... Quebec Some of the purposes provided by the Registraire des entreprises that are considered acceptable for non-profit incorporation are not considered charitable at law and therefore should not be included as purposes of an organization applying for charitable registration. ...

Payment for unused sick leave is considered a death benefit and is income of the estate or beneficiary who receives it. ... When the holder of a deposit or an annuity contract under a TFSA dies, the holder is considered to have received, immediately before death, an amount equal to the fair market value (FMV) of all the property held in the TFSA at the time of death. ... After the holder's death, the annuity contract is no longer considered a TFSA and all earnings after the holder's death are taxable to the beneficiaries in the year they receive this income. ...

A registrant, including a broker or other agent, who satisfies the above conditions may claim an input tax credit (ITC) for the amount that the registrant is considered to have paid as tax in error. ... For examples of how to determine the person who would be considered to be the constructive importer in various circumstances, refer to GST/HST Policy Statement P-125R Input Tax Credit Entitlement for Tax on Imported Goods available on the CRA Web site. ... If a person such as a broker or other agent is at any time reimbursed for the amount of an overpayment of tax, the person will not be considered to be out of pocket for the amount and will not be the person who is entitled under the legislation to recover the amount. ...

Under these Regulations, administrative services (as described in subsection 4(2)) that are provided by a "person at risk" would not be considered as a prescribed service (i.e., excluded from the definition of "financial service") for purposes of paragraph (t) of the definition of "financial service". Accordingly, where an insurance company supplies third party administrative services in respect of a SIBA but is not considered to be "a person at risk" (i.e., the insurance company does not underwrite a group insurance policy or issue a stop-loss policy), the supplies made pursuant to the ASO contract will be taxable. ... However, when an insurance company issues a stop-loss policy that covers one or more benefits contained in an employer's SIBA, the insurance company is considered to be "a person at risk". ...

Issue and Decision The transfer of money in exchange for property held as collateral for a loan is considered a financial service under paragraph 123(1)(g). ... If the property is not claimed within the redemption period, the property would be considered seized under subsection 183(1). ... Because the property was not claimed within the redemption period, it is considered seized for the purpose of satisfying a debt obligation pursuant to subsection 183(1). ...

Ruling Requested Is the collecting of tagged bags of garbage considered to be an exempt supply of a garbage collection service pursuant to paragraph 20(h)? Ruling provided The supply of the service of collecting the first tagged bag and any additional tagged bags is considered a supply of garbage collection services and would be exempt pursuant to paragraph 20(h). ... This is considered to be an exempt supply of garbage collection services pursuant to paragraph 20(h). ...