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For any interest paid by CCo to ECo in respect of the Charlie Debts, such interest will be considered to be derived by DCo pursuant to paragraph 6 of Article IV of the Treaty. ...

In connection with the s. 55(3.1)(b)(i)(A)(II) rule, CRA indicated that indebtedness of Foreign SpinCo will be considered to reduce the FMV of each property of Foreign SpinCo pro rata in proportion to the relative FMV of all property of Foreign SpinCo. ...

Holdco will declare and pay a dividend to ULC (which for Code purposes will be considered a dividend paid directly to U.S. ...

CRA ruled: The entering by the [Bank and its subsidiaries] into the Settlement Agreement and their voting in favour of the Plan, in and of themselves, will not result in any of [their] being considered to not deal at arm's length…with either the Trust or the Trustee. ...

The ruling summary indicates that Parent is considered to have de jure control of Lossco (notwithstanding that it does not have an immediate right to elect a majority of the directors of Lossco) and that this is "consistent with the decision of the SCC in Donald Applicators Ltd. (1969). ...

The ruling summary indicates that Parent is considered to have de jure control of Lossco (notwithstanding that it does not have an immediate right to elect a majority of the directors of Lossco) and that this is "consistent with the decision of the SCC in Donald Applicators Ltd. (1969). ...

Provided that a Partner would not, if his or her ServicesCorp did not exist, reasonably be regarded as an officer or employee of the Partnership in respect of the provision of Professional Services, the Partner's ServicesCorp will not be considered to be carrying on a personal services business as defined in subsection 125(7) of the Act. ...

No benefit will be considered to have been conferred by the Company on Parent or Direct Shareholder under s. 15(1) or 246(1) and no inclusion in Direct Shareholder's income under s. 56(2) of the Act, by reason of the reimbursements: (i) in respect of RSUs that were awarded prior to XX and that were not vested at the Effective Time, to the extent of the increase in the value of the RSUs after XX; and (ii) in respect of RSUs awarded on or after XX, all of the RSU value. ...

" Opinion that: [A]n election made by GPco under subsections 21(1) and (3)...in respect of the depreciable property held by MLP would be considered a valid election provided that GPco had authority to act for the MLP and the election was made or executed on behalf of GPco and each other person who was a member of MLP during the fiscal period. ...

Ruling that the related licence fee paid by Canco to Forco will be exempt under s. 212(1)(d)(vi), as "payment for distribution rights in this case are considered copyright royalties as the right to distribute is viewed as a component of the right to reproduce the software or is ancillary to such a right. ...