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In this connection, a leasehold interest which DC is subleasing to a third party will be considered to be a business property (para. 132(h)). ... In particular, "any amounts collected from customers and set up as deferred revenue under SAB 101 will not be considered a liability as there is no legal obligation to repay the amount or provide further services" (para. 134(c)(viii)). ... Payments made by DC to TC respecting the assumption by TC of deferred revenue obligations will be considered part of the property transfer for these purposes. ...

" Rulings: Provided that a Named Partner would not, if his or her New Contracting Corporation did not exist, reasonably be regarded as an officer or employee of Newco in respect of the provision of the relevant services, the Named Partner's New Contracting Corporation will not be considered to be carrying on a personal services business. Provided that Newco was not a member of a partnership in a particular taxation year and a particular New Contracting Corporation was not a member of a partnership in that same year, the income of Newco and the particular New Contracting Corporation for that taxation year will not be considered to be specified partnership income. ...

Rulings The share capital of FA will be considered to consist of two classes of shares. The distribution on FA shares will be considered to be in respect of two classes of shares of FA and will be deemed to be a dividend paid by FA and received by Canco pursuant to ss. 90(2) and (5) for the purposes of ss. 15(1), 90 and 113. ...

Rulings Canco1 and Canco2 will each be considered to be a qualifying substitute corporation as defined in s. 212.3(4). The Distribution will be considered to be received as a dividend in respect of a class of shares of capital stock of FA1 by the Taxpayers (Canco7, 8 and 9) for the purposes of s. 212.3(9)(b)(ii) – A(B). ...

Rulings The Taxpayers will be considered to be carrying on business in Canada in their respective taxation years during which their Assigned Employees are providing Services from the Province. However, they will not be considered to be carrying on business in Canada through a permanent establishment, as defined in Article 5 or V of the applicable treaty, solely as a consequence of such Services being provided by the Assigned Employees. ...

However, if at any time after the initial sale, the Dealer "services" the Client's account in order to earn the Dealer's Fee, or if the fee is paid to a Dealer who did not facilitate the initial sale of the […] Shares, the supply of the services for which the Dealer's Fee is paid may be considered the provision of a taxable supply. ... However, if the Dealer's services performed after the initial sale are predominantly to "service" the Client's account in order to receive the ongoing Dealer's Fee, then those services are considered in the nature of taxable management, administration, marketing or promotional activities as they are not themselves financial services.... ...

Such obtaining of the Court judgment will not, in and of itself, result in a disposition by the existing beneficiaries, of any part of their respective interests in Trust (including for the purposes of ss. 106(2) and 107(1)) nor will they be considered to have received proceeds of disposition as a result of the addition of the beneficiaries and, for greater certainty, s. 69(1)(b) will not apply as a result of this addition.. ... This is also true for the trustee/beneficiary who, in this particular situation, is not considered to have control over the decision to add a new beneficiary. ...

The renunciation by Daughter1 of her income interest in the Fund will not result in Daughter1 being considered to have received any proceeds of disposition for purposes of ss. 40(1), 106(2) and 107(1). The consent provided by Daughter1, Daughter2’s children and grandchildren will not result in any of them being considered to have received any proceeds of disposition for purposes of ss. 40(1), 106(2) and 107(1). ...

12 March 1997 Ruling 9641723- Mutual fund trusts- Special warrants-- summary under Paragraph 108(2)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(b) Special warrants are not considered marketable securities. ...

H (May 1993 Access Letter, p. 230)-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) RC is not aware of any situations where the application of s. 80.4 to loans between non-residents should be considered to produce an inappropriate result. ...