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Whether fees paid for the use of a dormitory room would be considered rent for purposes of computing the clergy residence deduction? ... You have also asked whether the fees paid for the use of a dormitory room would be considered rent for purposes of computing the clergy residence deduction. ... However, technical interpretation (TI) 2012-045596 considered the meaning of this phrase for purposes of paragraph 8(1)(c) of the Act, and noted that a principal place of residence is generally considered to be the place where an individual regularly lived, slept, received mail, etc., and in some cases, where the individual's immediate family also resided. ...

In addition, due to the requirement to establish gross negligence, the penalties provided by 163(2) are not being considered in these situations. ... Where a prescribed form received by CRA is considered invalid, it follows that it has not been filed as and when required by the Act. ... In that case it was stated that where a taxpayer has only provided limited information in a form, the form is considered to be invalid. ...

XXXXXXXXXX also argues that according to IT-128R paragraph 4(b) expenditures made to restore property to its original condition are considered to be current expense. ... The clean-up expenditures considered at the present time are incurred in respect of XXXXXXXXXX 2. ... XXXXXXXXXX 9.Revenue Canada has determined that a landlord's costs to remove asbestos are considered capital in nature rather than current expense. ...

S-Corp owned by a US resident individual are entitled to the 5% withholding rate under Article X(a) of the Canada-United States Tax Convention (Treaty) Position: The 5% rate is applicable where the S-Corp is, pursuant to Article X(2)(a), considered to own at least 10% of the shares of Canco, the dividends are considered to be derived by the S-Corp pursuant to Article IV(6), and the S-Corp is eligible for benefits under Article XXIX A of the Canada-United States Tax Convention (Treaty). ... You have asked us: (a) Whether the Treaty would apply to limit Canada's taxation to 5% of the gross amount of the dividend; and (b) Whether the S-Corp would be considered a qualifying person under Article XXIX A of the Treaty. ... Subparagraph 2(a) of Article X of the Treaty provides, that for the purpose of determining whether the beneficial owner of a dividend is a corporation that is a resident of a Contracting State that owns at least 10% of the voting stock of the company paying the dividend,... a company that is a resident of a Contracting State shall be considered to own the voting stock owned by an entity that is considered fiscally transparent under the laws of that State... in proportion to the company's ownership interest in that entity Under subparagraph 2(a), the S-Corp would be considered to own the shares of Canco owned by the US LLC. ...

Position: 1) Generally a tender offer (i.e. an offer which requires an acceptance by the holder in the form of a tender of the relevant obligation by the holder directly to the issuer) is not considered to be an open market repurchase for purposes of subsection 39(3). 2) Generally, a bond repurchase that is negotiated and concluded directly between an issuer and a holder is not considered to be an open market repurchase for purposes of subsection 39(3). 3) Generally, the exercise by the issuer of an early repayment right pursuant to the terms of a bond is not considered to be an open market repurchase for purposes of subsection 39(3). ... Generally a bond repurchase that is negotiated and concluded directly between an issuer and a holder is not considered to be an open market repurchase for purposes of subsection 39(3). Generally the exercise by the issuer of an early repayment right pursuant to the terms of a bond is not considered to be an open market repurchase for purposes of subsection 39(3). ...