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S. 51.1 will apply to the conversions in 1 and 5 such that Forco and the Partnership will be considered to dispose of the Notes for their ACB and to have reacquired them for the same amount. ...

., residential units) that must be considered and not supplies of services by it to the residents which must be taken into account in determining whether the head lease is exempt under section 6.1, so that the lease of the assisted-living Facilities would be exempt if the "substantially all" test was satisfied on this basis. ...

.… [W]hile some of the activities, such as processing credit applications, assist FinanceCo in providing a financial service of issuing a credit card and operating and maintaining cardholder accounts, when considered as a whole [the services] are predominantly administrative in nature including storage of account information, card production services, services related to cardholder data and contact centre services. ...

After ruling that the services of the ISO (which were a single supply including payment processing services) were excluded under s. 4(2), CRA stated:...when considered as a whole, the ISO's service is predominantly the transfer, collection or processing of information and/or an administrative service performed by a person who is not at risk (i.e., the ISO does not appear to be financially at risk when it provides assistance to the Merchant such as performing data processing, monthly reports, funds transfer and other support and administrative services). ...

Before ruling that GAAR would apply respecting transactions intended to avoid the application of the debt forgiveness rules to the non-capital losses of LossCo, rulings were provided that: the operation by AmalCo of the retained branches and the branches to be sold will constitute the carrying on by it of the LossCo business for purposes of s. 111(5)(a)(i); and that the income of AmalCo from the services referred to above "will be considered to be derived from the sale, leasing, rental or development, as the case may be, of similar properties or the rendering of similar services" to the services previously rendered by LossCo. ...

After giving favourable s. 111(5)(a) rulings, CRA ruled that s. 245(2) will apply on the basis "that the repayment of the subordinated debt...will be considered a settlement of the subordinated debt for no consideration for the purposes of applying section 80. ...

Rulings that Forco1 will be considered a corporation and that the ownership interests in it will be shares. ...

For instance, an e-mail address or an IP address obtained by a supplier that does not represent an actual specific physical address is not considered to be an address for purposes of the rule. ...

CRA ruled that monthly fees paid by the Customers to Corporation C for managing and maintaining components of the Customers' storefronts, for continuing access to the sales platform, and related support services, were (to the extent they otherwise could be considered to be management or administration fees or charges) not subject to Part XIII tax under s. 212(1)(a) by virtue of s. 212(4)(a) (as well as ruling that fees collected from Canadian home users were exempt from Part XIII tax under Art. ...

CRA rules that the taxpayers will not be considered to carry on business through a permanent establishment in Canada as a result of these activities for the purposes of the Canada-U.S. ...