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LLC would be considered a corporation, that the ownership interest of a member would be considered shares, and that distributions would be considered to be dividends. ...

Should Individual A be considered financially dependent on his father at the time of his father's death so that amounts could be transferred from the father's RRSP as a refund of premiums? CRA stated: Some of the factors which may be considered in making [the] financial dependency determination include the income of the child from all sources, the cost of living and the ability of the child to provide for self-support, and any support received by the child from other persons. … [I]f a child is living with another individual who is providing support for the child at the time of the annuitant's death, the child would not be considered to be financially dependent upon the deceased for support at that time. ... Consequently … Individual A would not be considered to be financially dependent on the deceased at the time of death for the purpose of a deduction under paragraph 60(l)….. ...

(b)(ii) of “foreign resource property” in s. 248(1), that “for such mineral right to be considered specified foreign property, the right would have to be tangible property, which is understood to include real property such as land and rights issuing out of, annexed to and exercisable within or about land,” and that the mineral right would be considered a tangible property coming within s. (b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. Therefore…a mineral right situated outside Canada would be considered a specified foreign property pursuant to paragraph (a)…. ...

In the event that, without being equivalent, the hourly rate of a volunteer firefighter is comparable to that of a regular firefighter, we are of the view that the amount paid would not be considered "minimal". As a result, the firefighter in this situation would not be considered to be acting as a volunteer for the purposes of subsection 81(4) and section 118.06. ... Thus, an individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06. ...

For various of the scenarios considered, CCRA indicated that the changes affected the insurance contract and not the plan. In another scenario, where there were separate contracts of insurance for employees in each province but the terms province-to-province were essentially the same, CCRA considered there to be one plan, so that there would not be a loss of continuity when an employee moved provinces. CCRA also stated [T]wo separate plans could co-exist to the extent that both: the plans are administered separately; the premium rate is determined separately for each plan; the amount of benefits, premium rates, terms of enrolment and other conditions of each plan do not depend on the existence of the other plan; there is no cross-funding between the two plans, i.e., the premiums or returns from one plan should not be used to fund the other plan; for example, if funds were already accumulated in the old plan and used to fund the new plan, then the new plan would be considered a continuation of the old plan; the administration of the plans should indicate that each plan can be considered separate from the other. ...

Are the parents considered to be specified beneficiaries of the trust under s. ... Thus, the parents would be considered to be beneficially interested in the trust and, consequently, they would satisfy the first condition of subparagraph (c.1)(ii) of the definition of "principal residence" in section 54. In addition, where a trust grants a person a right to inhabit a housing unit, owned by the trust, the person would be considered to have a beneficial interest in the trust. ...

Are the parents considered to be specified beneficiaries of the trust under s. ... Thus, the parents would be considered to be beneficially interested in the trust and, consequently, they would satisfy the first condition of subparagraph (c.1)(ii) of the definition of "principal residence" in section 54. In addition, where a trust grants a person a right to inhabit a housing unit, owned by the trust, the person would be considered to have a beneficial interest in the trust. ...

Y are considered, for the purposes of the definition of "qualified farm property" in subsection 110.6(1), to be the fathers of their children (natural, adopted or dependent before the age of 19), grandchildren and great-grandchildren, as well as the spouses or common-law partners of those persons. However, they are not considered to be the father of the brothers and sisters of the spouses or common-law partners of their children, grandchildren or great-grandchildren. ... Y will not be considered to be the father of his son's wife's sister, notwithstanding the fact that that person is considered to be his son's sister pursuant to paragraph 252(2)(c). ...

21 February 2012 External T.I. 2011-0417471E5 F- Changement d'usage- paragraphe 45(3)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property immovable (including a duplex used 2 different ways) is considered a single property unless subdivided A taxpayer inhabited as a principal residence a unit of a taxpayer-owned duplex and integrates that unit, through major renovations, with the other unit in the duplex that was, before those renovations, rented to third parties. CRA indicated that “An immovable is normally considered to be a single property unless it is legally subdivided into two or more separate properties,” so that, in this situation, the partial change-in-use rule in s. 45(1)(c) would be considered to apply. ...

Would LP1, LP2 and LP3 be considered to be dealing at arm’s length with Canco for purposes of Art. 11, subpara. 3 (c) of the Treaty? ... Pursuant to the Interpretative Protocol, whether persons are considered to be dealing at arm's length with each other… is determined by subsection 251(1).... [W]e will consider GP Co to control Holdco and Canco. … Folio S1-F5-C1 [states] “when a partner is not in a position to control a partnership and that partner has little or no say in directing the operations of the partnership, it is generally recognized that the partner is dealing at arm's length with the partnership.” … By analogy, you reason that a partner who is considered to be dealing at arm’s length with a partnership should also be considered to be dealing at arm’s length with the corporation controlled by the partnership. ...