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Interest from guaranteed investment certificates and other interest bearing certificates, such as treasury bills and bonds, is not generally considered to be earned on a reserve. ... For example, in the case of a government bond, regardless of where purchased, the interest will be considered earned in and paid from Ottawa. ...

Reasons FOR POSITION TAKEN: Consistent with the definition of "medical" in the Random House Dictionary (of or pertaining to the art of healing), the costs are considered to be of a medical nature for the purposes of paragraph 118.2(2)(a) of the Income Tax Act. In addition, the inability of an individual and her husband to become natural parents without artificial insemination is considered to be a disability for the purposes of paragraph 118.2(2)(o) of the Act. 941568 XXXXXXXXXX M. ...

Such income and benefits are considered to be property of an Indian on a reserve. In order to reach that decision the Court had to conclude that the situs of the debtor (being on a reserve) is not the sole factor to be considered in exempting income from taxation since unemployment insurance benefits are not paid from a reserve. ...

Such income and benefits are considered to be property of an Indian on a reserve. In order to reach that decision the Court had to conclude that the situs of the debtor (being on a reserve) is not the sole factor to be considered in exempting income from taxation since unemployment insurance benefits are not paid from a reserve. ...

Factors to be considered would include the location of the books and records, where the Directors meet, where day-to-day management and control is exercised, where major business transactions are carried out, where employees report for work or are hired or are paid from, and where one would sue if legal action were being contemplated. If the head office of a business meets most of the criteria set out above it would likely be considered that control and management is exercised there. ...

The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ... I would also like to point out that the employment duties of each particular Indian employee must be considered to determine if they were in connection with the employer's non-commerical activities carried on exclusively for the benefit of Indians who for the most part live on reserves. ...

Those issues were subsequently considered by the House of Commons Standing Committee on Finance in its report released on September 18, 1996. ... Any changes to tax policy would have to be considered by that department. ...

In your letter, you requested our opinion as to whether the partners in the hypothetical situation detailed below would be considered to be "specified members" as defined in subsection 248(1) of the Income Tax Act (the "Act").  In addition, you requested our views as to what is required for a partner to be considered to be involved in the partnership business on a "regular, continuous and substantial basis".  ...

An outright transfer of property may be considered to have been made, subject to the attribution rules in sections 74.1 and 74.2 of the Act, where a loan is not considered genuine. ...

This provision provides that benefits derived after 1987 from counselling services in respect of the retirement of an employee are no longer considered to be a taxable benefit. ... Advice relating to the purchase of specific investments or the promotion of a particular investment strategy is not considered to be retirement counselling. ...