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Under Canadian tax law, any shares distributed in such a way to Canadian shareholders are considered to be paid as dividends, which are subject to Canadian tax. ... In this regard, Finance officials have considered requests for amendments to the Act to exempt Canadian shareholders from tax on spin-offs undertaken by foreign corporations, but have concluded that amendments are not appropriate. ...

Under Canadian tax law, any shares distributed in such a way to Canadian shareholders are considered to be paid as dividends, which are subject to Canadian tax. ... In this regard, Finance officials have considered requests for amendments to the Act to exempt Canadian shareholders from tax on spin-offs undertaken by foreign corporations, but have concluded that amendments are not appropriate. ...

Reasons: Shares distributed by a corporation to its shareholders on a pro-rata basis are considered as dividends for Canadian tax purposes. ... Accordingly, your request would have to be considered by that department. ...

As a guideline, the intangible benefit from those events costing up to $100 per person will be considered to be non-taxable. Ancillary costs, such as transportation home, may increase the amount considered reasonable. ...

Pursuant to paragraph 96(1)(f) of the Act, the income of the partnership is considered to retain its identity when flowing through to the partners. ... Subparagraph 115(1)(b)(iv) of the Act describes the condition which would require shares of a public company to be considered "taxable Canadian property":      "a share of the capital stock of a public corporation if...not less than 25% of the issued shares...belonged to the non-resident person, to persons with whom the non-resident person did not deal at arm's length... ...

Leung   (613) 957-2116 October 30, 1989 Dear Sirs: Re:  Paragraph 54(b) of the Income Tax Act (the "Act") We are writing in response to your letter of September 28, 2989 wherein you requested our view on whether, for purposes of subsection 80(1) of the Act, "cash" would be considered capital property within the meaning assigned by paragraph 54(b) of the Act. ... It is therefore, our opinion that, for purposes of subsection 80(1) of the Act, money in Canadian currency would not normally be considered capital property within the meaning assigned by paragraph 54(b) of the Act. ...

Provided that subparagraph 40(2)(g)(ii) does not apply and the conditions of paragraph 39(1)(c) are met this loss would be considered a business investment loss.  Otherwise the loss would be considered to be a capital loss.  Paragraph 3 of IT-484R discusses the relevant conditions that must be met in order that a particular capital loss may qualify as a business investment loss. ...

In addition, you want to know if we agree that the beneficiary would not be considered to have disposed of his income interest in the trust paragraph 248(8)(c) of the Act notwithstanding that the release or surrender described above might also be considered to be a "renunciation" for purposes of paragraph 6 of IT-385R. ...

More specifically, you ask whether the Department of Indian Affairs and Northern Development and its Regional Office in Edmonton are considered to be off-reserve employers. ... Therefore, native employees of the Department of Indian Affairs and Northern Development are considered to be employed by an off-reserve employer. ...

The central management and control of an organization is considered to be exercised by the group that performs the function of a Board of Directors of the organization, in the case of a school division this would be a Board of Trustees, and may be exercised in a place other than the principal administrative office of the organization. ... If you feel that there are significant changes to the facts pertaining to the XXXXXXXXXX or if you have any additional information that should be considered in your particular case, I would suggest you write to the Winnipeg District Taxation Office at the following address: 325 Broadway Avenue Winnipeg, Manitoba R3C 4T4 In closing, as indicated in my December 15, 1993, letter attached to the guidelines I welcome comments concerning them until March 31, 1994. ...