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It is a question of fact whether a particular fee is reasonably considered to relate solely to the year. For example, a one-time fee related to a loan with a term longer than one year, such as a loan-structuring fee or loan-placement fee, is not reasonably considered to relate only to the year in which the loan was made. ... In that situation, the expense will normally be considered to be incurred in the course of the issuance. ...

Generally, the non-resident withholding tax is considered your final tax liability on the income. ... If you send us your return after the due date, your election will not be considered valid. The 23% non-resident withholding tax will be considered the final tax liability. ...

You resided outside Canada on December 31, 2018, but kept significant residential ties with Canada; you may be considered a factual resident of Canada. ... You resided outside Canada on December 31, 2018, and are considered a deemed resident or a non-resident of Canada. ... You are still considered to have a spouse or common-law partner if you were separated involuntarily (not because of a breakdown in your relationship). ...

Logging operations are generally considered to encompass any of the following: (a) cutting or "felling" trees in the woods, (b) trimming off branches and tops, (c) "bucking" into desired log lengths, (d) transporting logs to tidewater, or some other central gathering point, e.g. dry land sort, and (e) booming, rafting, or loading onto barges for towing to the mill. ...

Enter on line 128 the taxable alimony or maintenance payments you received or are considered to have received in 1995. ...

Logging operations are generally considered to encompass any of the following: (a) cutting or "felling" trees in the woods, (b) trimming off branches and tops, (c) "bucking" into desired log lengths, (d) transporting logs to tidewater, or some other central gathering point, e.g. dry land sort, and (e) booming, rafting, or loading onto barges for towing to the mill. ...

As a general rule, a taxpayer who takes commodity futures positions in, or who has transactions in, a commodity connected with a business, is considered to be trading as part of the business operations and the comments in 3 above apply. ... As an example, a jeweller who buys 100 ounces of gold for a business (a normal amount for that business) and also makes additional purchases of 1600 ounces of gold, or of futures contracts representing 1600 ounces of gold, as a speculation for his or her own account, may be viewed as a speculator with respect to the additional purchases when all the facts of the situation are considered. ... However, the comments in 4 above must be applied in respect of each member of the partnership and if one member can be considered an insider then the income treatment is required for the partnership. 18. ...

Pursuant to subsection 104(24), an amount is not considered to be payable in a taxation year unless it is paid in the year to the person to whom it is payable or the person to whom it is payable is entitled in the year to enforce payment thereof. ... It should be noted that foreign accrual property income of a non-resident trust is included in the income of a beneficiary pursuant to paragraph 104(13)(c) to the extent that the amount may reasonably be considered to have become payable to a beneficiary within the meaning of subsection 104(24). ... The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. ...

Once such an amount on account of the sale price exceeds the adjusted cost base of the shares (as reduced by any previous such amounts), the excess is considered to be a capital gain that is realized at the time that that amount became determinable, and the adjusted cost base becomes nil. ... Where the sale agreement stipulates a minimum amount payable by the purchaser in any event, that amount is considered to become determinable by the vendor at the time of the sale. ¶ 6. ... For the purposes of this bulletin, an agreement that merely determines when amounts are to be paid, as opposed to determining the quantum of proceeds, is not considered to be an earnout agreement. ¶ 9. ...

The transfer of the Settlement Payment to the RRSP or RRIF to correct the error will not be considered a contribution, and no deduction will be permitted for the amount transferred. ... If you received the Settlement Payment in respect of shares held in your RRSP or RRIF and choose not to transfer the cash and shares to your RRSP or RRIF, the cash payment and the fair market value of the shares will be considered income and must be included on your tax return as an RRSP or RRIF benefit received in the year. 2. ... Since you no longer owned any of your Original Shares when you received the Settlement Payment, you are considered to have received additional proceeds of disposition from having disposed of your Original Shares. ...