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NPO1 and NPO2 have asked for a ruling that, notwithstanding the lease arrangement, they will still be considered to be organized exclusively for non-profit purposes within the meaning of paragraph 149(1)(l) of the Act? ... Under the PCA, the Taxpayers are considered "corporations". ... Notwithstanding the Lease, NPO1 or NPO2 will still be considered to be organized exclusively for non-profit purposes within the meaning of paragraph 149(1)(l) of the Act. ...

Principal Issues: 1)whether 254(a) applies to the purchase by an RCA trust of annuities providing periodic payments for life & a lump sum for guaranteed portion for the spouse of a deceased employee; 2)whether the employer may loan (i.e. it won't be considered a contribution) the amount needed by the RCA trust to make up the difference between the RCA assets and the price of the annuities (loan to be repaid by the amount of refundable tax the refund of which is triggered by the purchase of the annuities); 3)whether the annuities will be considered subject property of the RCA thereby preventing refund of Part XI.3 tax to custodian after final return filed. ... RULINGS Provided the above statement of facts and proposed transactions are accurate and constitute a complete disclosure of all the relevant facts and provided the transactions are completed as proposed, we rule as follows: A.The amount loaned by the Company to the Custodian of the RCA will not be considered a contribution to the RCA for purposes of the Act. ... D.The annuities purchased by the RCA in the name of the Beneficiary will not be considered subject property of the RCA for purposes of Part XI.3 of the Act. ...

Any interest or other additional amounts that may reasonably be considered to have accrued for the benefit of a Participant to the end of a taxation year (calendar year) shall be paid in that year to the Participant. Such amounts paid to the Participant will be considered employment income for the purposes of the Act and will be reported on the Participant's T4 supplementary and shall be subject to tax withholdings. 12. ... Such amounts paid to the Participant will be considered employment income for the purposes of the Act and will be reported on the Participant's T4 supplementary and shall be subject to tax withholdings. 15. ...

In addition, they could not be considered to be all or substantially all attributable to support activities such as engineering or design, operations research, mathematical analysis, computer programming or psychological research.  ... From the above, it appears that generally bidding costs, whether successful or unsuccessful, do not satisfy the requirements in paragraph (c) and would not be considered directly attributable to the prosecution of SR & ED.  ... Each expenditure must be considered on its own merits for purposes of Section 2900 or the Regulations.  ...

(c) XXXXXXXXXX (d) Whether the severance payments would be considered as "salaries and wages" for the purposes of subparagraph 402(3)(a)(ii) of the Regulations? ... Accordingly, it is our view that the severance payments would not be considered as "salaries and wages" for the purposes of subparagraph 402(3)(a)(ii) of the Regulations. ... All actions of Agentco will be considered as actions of the Project Owners as principals. ...

The provisions of the deed of constitution are considered to have been accepted by unitholders of the CCF as a term of the acquisition of the units. ... Neither the Fund nor any of the Sub-Funds will be considered to be a trust to which subsection 94(1) of the Act applies. ... For the purposes of computing any capital gain or capital loss under Part I of the Act by a Unitholder of a Sub-Fund, the redemption of Sub-Fund Units by the Unitholder will be considered to result in a disposition of the Unitholder's proportionate undivided interest in the property of the Sub-Fund. ...

Will the members holding membership units of the Dutch Cooperative (DC) be considered to hold "shares" for the purposes of the Act? ... Will the BV be considered to have disposed of any of its property on its conversion to a DC? ... On its conversion into DC, BV will not be considered to have disposed of any of its property for the purposes of the Act. ...

Whether, after conversion, the LLC is considered the same entity as the corporation. Whether, after conversion, the LLC will be considered a corporation for purposes of the Act. ... D Co, as an LLC organized under the DLLCA, will be considered to be a corporation for the purposes of the Act. ...

Whether, after the conversion, the LLC will be considered to be the same corporation as the Delaware corporation. 2. ... An LLC is considered to have a separate legal existence from its members. ... The Proposed Transactions will be considered non-recognition transactions and will be tax-deferred for purposes of the IRC. ...

Are all the rental lease amounts that are prepaid considered income and can a yearly reserve be taken? ... The rent prepaid by the Trust to B Co pursuant to the Concurrent Leases will be considered to be prepaid rent for the purposes of the Act and, for greater certainty, will not be considered to be payments made by the Trust in respect of the extension of the XXXXXXXXXX Option or the XXXXXXXXXX Option, as the case may be. ... The prepaid rent referred to in Ruling D above, that is, in respect of the Concurrent XXXXXXXXXX Lease, will be deductible by the Trust in computing its income on a straight-line monthly basis over the remaining term of the lease, provided that, for this purpose, the first taxation year of the Trust shall be considered to commence with the date that the Concurrent XXXXXXXXXX Lease is entered into by the Trust and B Co and the last taxation year of the Trust will be considered to end on XXXXXXXXXX. ...