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Should the borrowing be considered to be, in substance, a liability of XXXXXXXXXX? ... Consequently, it is not an avoidance transaction and the borrowing will not be considered to be a liability of XXXXXXXXXX. ... The XXXXXXXXXX will not be considered to be a liability of Bco and, accordingly, no amount in respect of the XXXXXXXXXX will be required to be included in computing the capital of Bco pursuant to subsection 181.2(3) of the Act. ...

A corporation that is for all purposes an agent of the provincial Crown and whose property and income is property of Her Majesty in right of the province is not liable to taxation, since any income of the corporation would be considered income of the provincial Crown. ... To the best of your knowledge and that of the taxpayers involved, none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with an income tax return already filed and none of the issues is under objection or appeal. ... Further, in order for an expenditure to be considered a gift, it must be made without conditions, from detached and disinterested generosity, out of affection, respect, or charity or like impulses, and not from the constraining forces of any moral or legal duty. ...

Unless special work site exclusion applies, value of tickets is considered a taxable employment benefit. ... You ask whether the purchase of the tickets by the employees using the Air Miles obtained from the employer would be considered taxable employment benefits to the employees, especially in light of our new policy on employer-provided gifts. ... Cash or near-cash gifts would not be covered by this policy, and the value of such gifts would therefore be considered taxable employment benefits notwithstanding the cost of the gifts. ...

We understand that, to the best of your knowledge and that of the taxpayers involved: (a) none of the matters considered in the requested ruling is being considered by an office of Revenue Canada, in connection with a tax return already filed; and (b) none of the matters considered in the requested ruling is under objection or appeal. ... However, should such activities constitute carrying on business in Canada, the income from such a business will be considered to arise in Canada. ...

In responding to your queries, I have addressed only the issue of whether contributions of property may be considered to be SR & ED expenditures.  I have not considered, for instance, whether the projects referred to qualify as SR & ED since that did not appear to be your concern. ... With respect to the Silviculture for Integrated Resource management project, it appears that the involvement off would be sufficient to have it considered to be a joint participant.  ...

It is our opinion that all members of a partnership, whether general or limited, are considered to be carrying on the business of the partnership.  Therefore, the part of the sentence in paragraph 4 of IT-73R3 that stated "A share of income from an active business of a partnership is considered to be income of a corporate partner (whether a general or a limited partner) from an active business" is still applicable.  ... For the purpose of section 95 of the Act, all members of a partnership are considered to be carrying on the business of the partnership.  ...

The commercial trust units would be considered as foreign property, but, the 25-year promissory notes would not be considered as foreign property. ... The CT will be considered as a unit trust pursuant to paragraph 108(2)(a) of the Act. ... The MFT will be considered as a unit trust pursuant to paragraph 108(2)(a) of the Act. ...

Principal Issues: Are "special warrants" considered marketable securities for purposes of 108(2)(b)? ... Holloway Attention: XXXXXXXXXX March 12, 1997 Dear Sirs/Mesdames: Re: XXXXXXXXXX We are writing in reply to your letters of December 16, 1996 and January 29, and February 28, 1997, in which you requested a ruling that "special warrants" could be considered to be "marketable securities" for purposes of subparagraph 108(2)(b)(iii) of the Income Tax Act. ...

The Children will not be considered to have received any proceeds of disposition for the purpose of subsection 107(1) of the Act as a result of the proposed transactions.” ... The Children will not be considered to have received any proceeds of disposition for the purposes of subsections 40(1) and 107(1) of the Act as a result of the proposed transactions.” ...

Accordingly, in the above situation, where there is only one employee covered in the plan and as the plan is not a private health services plan, we are of the view that the plan would not be considered to be health and welfare trust and the exception in subparagraph 6(1)(a)(i) of the Income Tax Act (the "Act") would not be applicable. ... As a consequence, the individual would be considered to be in receipt of a taxable benefit under subsection 15(1) of the Act. ...