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In particular, you have asked whether the corporation would be considered resident on a reserve such that Guideline 2 applies to exempt the income of its employees. ... Central management and control of an organization is normally considered to be exercised by the group that performs the function of a Board of Directors of the organization. ...

Isuuing of shares could be considered a constructive payment. DM'S OFFICE (2) ADM 950842 ASSOCIATE DEPUTY MINISTER (1) ADM'S OFFICE (2) RETURN TO 15TH FLOOR, ALBION TOWERS June 19, 1995 XXXXXXXXXX Dear XXXXXXXXXX: I am replying to your letter of June 9, 1995, wherein you requested confirmation that private retailers, who are not organized as co-operatives, may, in computing income, deduct the amount of patronage dividends paid to customers, and that the payment may be made by the issuance of shares without the need for exchange of paper. ... Other business aspects such as the dilution of shares, possible effects on financing arrangements and the detailed accounting required must be considered. ...

Such travel is considered a personal activity and as such the costs associated with it would be considered a personal or living expense. ...

It is the CCRA's position that a particular place does not necessarily need to be licensed as a nursing home in order to be considered as such, but it must have sufficient staff to operate as a nursing home. ... Since tax policy issues and recommendations to amend the legislation are the responsibility of the Department of Finance, they would have to be considered by that department. ...

Specifically you inquire whether you are considered property for purposes of section 9 of the Act. ... I can assure you that, despite your concerns, for purposes of this provision an individual is not considered property. ...

Day   (613) 957-2136 June 7, 1990 19(1) We are writing in reply to your letter of May 8, 1990, wherein you requested our views as to whether or not a cash donation to the Province of New Brunswick would be considered to be a gift to Her Majesty in right of a province, and thus would not be restricted to the 20 percent of income limitation imposed by subsection 118.1(1) of the Income Tax Act. 24(1) Our comments Whether or not a donation, such as the one described above, could be considered to be a gift to Her Majesty in right of New Brunswick would involve a finding of both fact and law. ...

Paragraph 14 of IT-270R states that an amount of tax paid that will be refunded to the taxpayer is not considered to be tax paid for the year. ... The amount withheld is generally not considered to be an assessment or a levy of tax as such and thus the entire amount may not be an amount of "tax" paid. ...

.-     payments from the Director, ESA, to an individual under the terms of the ESA would be considered a payment from an RCA to be included in income pursuant to paragraph 56(1)(x) of the Act.-      payments from the Director, ESA, to the corporation under the terms of the ESA would be taxable to the corporation pursuant to paragraph 12(1)(n.3) of the Act.-     payments received by an individual would be considered to be retiring allowances out of an RCA for the purposes of paragraph 60(j.1) and would be eligible for a roll-over to an RRSP.-     the amount of interest paid to an individual by the company would be a retiring allowance under paragraph 56(1)(a) and would be eligible for an RRSP roll-over under 60(j.1). 21(1)(b) We trust the above comments will be of assistance to you. ...

AS IT APPEARS THAT THE LIFE INSURANCE PROCEEDS WILL BE PAID OUT AS DIVIDEND TO FUND THE BUY-SELL AGREEMENT, IT IS THE DEPARTMENT'S VIEW THAT THE  LIFE INSURANCE POLICY WOULD NOT BE CONSIDERED TO BE AN ASSET USED IN AN ACTIVE BUSINESS. ... RESPONSE EACH SHARE IS CONSIDERED TO BE A SEPARATE PROPERTY SO IT IS POSSIBLE TO ELECT ON SOME AND NOT OTHERS AND DOUBLE UP THE EXEMPTION. ... SHARES AND NOT OTHERS AS EACH SHARE IS CONSIDERED TO BE A SEPARATE PROPERTY.  ...

This is contrary to the Department's position set out in paragraph 10 of IT-159R3, according to which a debt is considered bad for the purpose of section 50 only when the whole amount is uncollectible or when a portion of it has been settled and the remainder is uncollectible. Otherwise, where a portion of a debt can be considered uncollectible, this portion is not considered to be bad for the purpose of section 50, even though the accounting practice may require a write-down to realizable value. ...