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When such a loan comes up for renewal, the loan then may be considered to be a loan to which section 80.4 of the Act applies. ...

As a result, these amounts would be considered to be "investment income" as defined in subsection 110.6(1) that would offset the amount of the benefit included in "investment expense" as defined in subsection 110.6(1) of the Act. ...

Only "qualified activities" may be considered in the calculation of a corporation's M & P profit and section 5202 of the Regulations provides an exhaustive definition thereof which may be paraphrased as follows: "qualified activities" means (a)      any of the following activities... in connection with manufacturing or processing... ...

You have inquired as to whether a change or exemption from such treatment could be considered. ...

It is also your understanding that an underground extension of an existing coal seam cannot be considered to be a new mineral resource. ...

It is, however, our view that a group of persons will be considered as having collectively acquired control where there is evidence that they have a common link or interest or they act together to control the corporation. ...

Capital cost allowance with respect to the property may not be claimed while a subsection 45(2) election is in force since the property is considered a personal use property. ...

If it cannot be considered to be any of these, the provisions of section 80 of the Act would apply.  ...

The opinions expressed here are not rulings and are not considered binding on the Department as outlined in paragraph 24 of Information Circular 70-6R. ...

Thus in this case, as D Co is only related to a Co by virtue of the deeming rule in subsection 251(3) it would not be considered to be related to A Co for purposes of applying subsection 251(3) to determine whether D Co and C Co are deemed to be related to each other by virtue of both such corporations being related to the same corporation, i.e. ...