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When employment outside Canada is not considered pensionable under subsection 16(1) of the Canada Pension Plan Regulations and there is no social security agreement, the employer or worker still has the option of including the employment in pensionable employment. ... In making a determination of a person's residence status, all of the relevant facts must be considered, including residential ties with Canada and length of time, object, intention, and continuity with respect to stays in Canada and abroad. Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status, explains the factors considered in determining an individual's residence status. ...

Maintenance costs, storage costs and selling costs are not included in determining the adjusted cost base under the Income Tax Act and are, therefore, not considered improvements under the Excise Tax Act. ... However, since the storage cost is not an expenditure that is capitalized according to generally accepted accounting principles it is not considered to be "in respect of the property" as that term has been interpreted. ... However, since the towing cost is not an expenditure that is capitalized according to generally accepted accounting principles it is not considered to be "in respect of the property" as that term has been interpreted. ...

A builder that satisfies either of these criteria is considered to be a large business even if the builder does not have a permanent establishment in Ontario or B.C. ... This includes consideration for supplies made by an associated person that is a GST/HST registrant, but that is not, on its own, considered to be a large business. ... Motor fuels acquired or brought into B.C. are eligible for a point-of-sale rebate of the provincial part of the HST, so are not considered to be specified property for RITC purposes. ...

In order to be considered a WLRP all of the following conditions must be met: The employer funds any part of the plan. ... Plans that are funded on an ongoing basis are generally considered not to be based on insurance principles. ... When employees are obligated to pay all the costs of a plan, the plan is considered to be an employee-pay-all plan. ...

Transitional tax adjustment Under the HST transitional rules, a builder may be considered to have collected a transitional tax adjustment for certain sales of new housing in P.E.I. ... A builder who is considered to have made a self-supply of new housing has to account for the GST/HST that the builder is considered to have collected on that self-supply by reporting that tax in its GST/HST return, even if the builder is a non-registrant. The amount of the GST/HST that a builder is considered to have collected is calculated on the fair market value of the new housing (building and land) as of the date of the self-supply. ...

There are many factors to be considered, none of which is in itself determinative. ... These items should be considered in conjunction with other residential ties. ... The spouse and dependants will be considered non-residents on the date they leave Canada. ...

The date a return is considered to be filed and the date tax is considered paid are subject to different rules in the Act, as explained in paragraphs 16, 17 and 21 of this memorandum. ... The date of the postmark is considered to be evidence of that day. 17. ... The date of the teller's stamp will be considered as the date received. ...

Rulings Requested Is the builder considered to have made a taxable sale of the complex to the individual? ...

Accordingly, the supply of an easement otherwise than by way of sale, may be considered a "similar arrangement" to a lease or licence. ... Ruling Given Depending on the nature of the agreement, the supply at issue may be considered a supply by way of sale or a supply by way of a lease, licence or similar agreement. ... Where the supply is in the nature of an easement, the supply would be considered an arrangement similar to a lease or a licence. ...

A bar that has fruit flavouring may also be considered to fall within this category. A cereal bar with a fruit filling is generally not considered to be a fruit bar. ... If the main ingredient in a nut bar is fruit, then the bar is considered to be a fruit bar and is taxable. ...