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Note If you were a resident (including a deemed resident) of Canada in 2000 but, under a tax treaty, you were considered a resident of another country, you may be a deemed non-resident of Canada for tax purposes in 2000. ... You were a deemed resident of Canada for tax purposes in 2000 if you did not have residential ties in Canada, but you stayed here for 183 days or more in 2000 and, under a tax treaty, you were not considered a resident of another country. ... If so, though we may consider you to be a deemed resident of Canada, under Quebec law you may also be considered a deemed resident of that province. ...

Note If you were a resident (including a deemed resident) of Canada in 2001 but, under a tax treaty, you were considered a resident of another country, you may be a deemed non-resident of Canada for tax purposes in 2001. ... You were a deemed resident of Canada for tax purposes in 2001 if you did not have residential ties in Canada, but you stayed here for 183 days or more in 2001 and, under a tax treaty, you were not considered a resident of another country. ... If so, though we may consider you to be a deemed resident of Canada, under Quebec law you may also be considered a deemed resident of that province. ...

The relevant factors to be considered in making such a determination will differ with the nature and extent of the activity or undertaking. ... When an artist creates a work of art with the intention of selling it but instead donates it to another person, the donation is considered to be a disposition of a property from the artist's inventory. The donation by an artist of other property (e.g., diaries or correspondence) would be considered to be a disposition of capital property. ...

The relevant factors to be considered in making such a determination will differ with the nature and extent of the activity or undertaking. ... When an artist creates a work of art with the intention of selling it but instead donates it to another person, the donation is considered to be a disposition of a property from the artist's inventory. The donation by an artist of other property (e.g., diaries or correspondence) would be considered to be a disposition of capital property. ...

The relevant factors to be considered in making such a determination will differ with the nature and extent of the activity or undertaking. ... When an artist creates a work of art with the intention of selling it but instead donates it to another person, the donation is considered to be a disposition of a property from the artist's inventory. The donation by an artist of other property (e.g., diaries or correspondence) would be considered to be a disposition of capital property. ...

You were a deemed non-resident of Canada in 2020 if you would have been considered a resident of Canada (or a deemed resident) but, under a tax treaty, you were considered a resident of another country. ... In addition to being considered a deemed resident of Canada, under Quebec law you may also be considered a deemed resident of that province. ... Your payment will be considered received on time if it is received on the first business day after the due date. ...

[Footnote 1] Accordingly, the comments of the FCA in respect of paragraph 251(5)(b) may be considered to be obiter dicta. ... Where a person is considered a resident of both Contracting States, Article IV will generally provide a mechanism to attempt to resolve the question of dual residence so that the person can be considered a resident of one of the Contracting States. ... Some examples found in the draft version were eliminated because they were considered redundant while others were eliminated because it was considered unreasonable to try to assume facts around the example in order to make the paragraph 95(6)(b) analysis. ...

[Footnote 1] Accordingly, the comments of the FCA in respect of paragraph 251(5)(b) may be considered to be obiter dicta. ... Where a person is considered a resident of both Contracting States, Article IV will generally provide a mechanism to attempt to resolve the question of dual residence so that the person can be considered a resident of one of the Contracting States. ... Some examples found in the draft version were eliminated because they were considered redundant while others were eliminated because it was considered unreasonable to try to assume facts around the example in order to make the paragraph 95(6)(b) analysis. ...

For this purpose, "payable" is considered to mean accrued and owing. ¶ 2. ... If the terms of the original issue of an obligation permitted those terms to be altered, any alteration in accordance therewith is not considered to result in a new obligation. ... Similarly, court decisions subsequent to the date of the IT should be considered when determining the relevancy of the comments in the IT. ...

Chaplains in hospitals, jails, the armed forces and other such organizations are generally considered to minister to congregations. ... Teaching is not considered to be administrative service, whether or not it is at a denominational school, college or seminary. ... This contrasts with the situation considered in Kraft et al. v. The Queen (see Appendix B). ...