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The Department's views may be helpful in the interpretation of certain phrases used in the opening words of subsection 18(1) and in paragraph 18(1)(a), but it should be remembered that these phrases must also be considered in relation to the wording of the paragraph as a whole. ... For comments on when the carrying on of a business may be considered to have commenced see IT-364- Commencement of Business Operations. 3. ...

Thus, an item such as a typewriter which might be considered a tool, is properly regarded as machinery and is placed in class 8. ¶ 5. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...

The size, quantity and dollar value of machinery or equipment used in the particular place are some of the criteria to be considered in the determination of "substantial". ... A permanent establishment will not be considered to exist in a province solely by reason of the fact that a bus or truck travelled through that province. ... Generally, subject to the comments in the current version of IT-420, Non-Residents- Income Earned in Canada, rental income of a corporation will be considered to constitute income from a business. ...

When an artist, author or composer creates a work of art, literary manuscript or musical composition with the intention of selling it, but later donates it to another person, the donation is considered to be a disposition of property from inventory. However, the donation by an artist, author or composer of certain other types of property (e.g. diaries or correspondence) is considered to be a disposition of capital property. ... Donations of property that are considered to be dispositions of capital property are subject to the same general provisions outlined in 1 to 5 above. ...

For this purpose, the word "gift" is not considered to include a property received as a bequest under the will of a deceased taxpayer or under the terms of a testamentary trust, even where the deceased taxpayer was the settlor of (or other contributor to) the inter vivos trust receiving the property. 9. ... A reasonable time will usually not be considered to extend beyond the end of the taxation year following the year in which the debt or obligation became payable by the trust. However, where subsect ion 104(18) applies with respect to the income of a trust in which a minor beneficiary has a vested interest, a reasonable time will usually not be considered to extend beyond the end of the taxation year following the year in which the child reaches the age of majority. 13. ...

Consequently, expenses incurred in attending a convention held outside the geographical limits of the sponsoring Canadian organization will normally not be deductible in computing income and, for this purpose, a convention held during an ocean cruise is considered as being held outside Canada. ... It should be noted that expenses incurred by or for a spouse or children accompanying the taxpayer to a convention or a combined convention and vacation trip are normally considered to be personal and, as such, are not deductible. ... The employees of an association organizing a convention would be considered as attending an intracompany meeting. ...

Only requests relating to tax years ending in any of the 10 calendar years before the year you make the request will be considered. For example, a request made in 2006 must relate to the 1996 or a subsequent tax year to be considered. ... For example, a request made in 2006 must relate to the 1996 or a subsequent tax year to be considered. ...

Consequently, expenses incurred in attending a convention held outside the geographical limits of the sponsoring Canadian organization will normally not be deductible in computing income and, for this purpose, a convention held during an ocean cruise is considered as being held outside Canada. ... It should be noted that expenses incurred by or for a spouse or children accompanying the taxpayer to a convention or a combined convention and vacation trip are normally considered to be personal and, as such, are not deductible. ... The employees of an association organizing a convention would be considered as attending an intracompany meeting. ...

However, since the business of a corporation depends upon its corporate existence, where any positive step is taken toward the formal dissolution of the corporation, it is considered to be winding-up or discontinuing its business as well. ... Where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. ... To minimize the problems that could ensue from the difference in timing, "immediately before the winding-up" for a particular disposition will be considered to mean immediately before that particular disposition. 8. ...

The size, quantity and dollar value of machinery or equipment used in the particular place are some of the criteria to be considered in the determination of "substantial". ... A permanent establishment will not be considered to exist in a province solely by reason of the fact that a bus or truck travelled through that province. ... Generally, subject to the comments in the current version of IT-420, Non-Residents- Income Earned in Canada, rental income of a corporation will be considered to constitute income from a business. ...