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In our view this "reasonably be considered to relate" test must be applied on a case by case basis in that the details and facts will differ from case to case. The fact that other assets have been pledged and that the lender in accordance with industry practice requires collateral in excess of the loan balance would be the type of factors to be considered in applying the test. ... Accordingly, we agree that the remarks in PS 83-16 may be considered a better guide, as to the amount of the insurance premium which may "reasonably be considered to relate" to the loan, than the remarks in IT 309R paragraph 7. ...

For example, a housing loan amortized over 25 years, renewable every five years, at a prescribed rate of interest would be considered acceptable while a non-interest bearing housing loan with a 15 year repayment term would be considered much less so. We are, therefore, unable to provide you with a definitive reply as to whether the type of arrangement described would be considered bona fide without taking into account the circumstances of a particular employee. It follows, also, that any change to the repayment arrangement that would bring it closer to one that is available in normal commercial practice would increase the likelihood that it would be considered bona fide. ...

Therefore an amount is considered to be deductible in the year it is capable of being deducted. If an amount is added to the cost of inventory, and the addition is not elective in nature, the outlay or expense is not considered to be "deductible". If the taxpayer has no option as to whether or not to deduct an expense, that is, he must capitalize the outlay, the amount will not be considered to be "deductible" and section 78 would not apply. ...

.- USCo is a U.S. incorporated company and it is considered to be a U.S. resident for U.S. domestic income tax purposes.- Since USCo's directors are Canadian residents and they exercise immediate, direct and detailed control over the activities of the company, its mind and management are considered to be in Canada. Therefore, for purposes of the Act, USCo is considered to be a Canadian resident.- USCo has a fiscal year end of December 31 and was subject to the Canada-U.S. ... Therefore, as of January 1, 1986 USCo will not be considered a resident of Canada for the purposes of either the Convention or the Act. ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ... When these factors are considered in the context of the FIT / microFIT Programs, it is our view that the income under the scenario described above would not be considered incidental to a farming business. ...

Finally, you have considered the rule contained in paragraph 87(2)(l.3) of the Act which, in the case of a new corporation formed upon amalgamation, provides that the new corporation will be considered to be a continuation of the predecessor corporation for purposes of the replacement property rules. ... " Interpretation Bulletin IT-259R4, Exchanges of Property, states in paragraph 9 that "a taxpayer is considered to have acquired replacement property at the time the acquisition would ordinarily be considered to have been made under the provisions of the Act and the general principles of law". ... Each situation must be considered on its facts. We trust these comments are of assistance. ...

You have asked whether the RV park would be considered to be a replacement property for purposes of the replacement property rules of the Act. ... To be considered a replacement property, the particular property must meet all the requirements outlined in the definition in subsection 44(5) of the Act. ... A taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a similar business. ...

Assume the loan can be considered debt. (3) The loan above is subsequently repaid in full. ... For the purposes of Part A (2), we are to assume that the loan can be considered to be debt. ... Therefore, the repayment of the loan would be considered a transfer of property to the trust from the beneficiary. ...

Position: Tax credits are not considered to be taxes paid but are considered when utilized to first apply to taxes on the source of income to which they are attributable. ... Alternative 3 Tax credits are not considered to be taxes paid but are considered when utilized to first apply to taxes on the source of income to which they are attributable. ... Under Alternative 3 tax credits are not considered as taxes paid therefore no foreign tax is considered to be paid on the interest or the capital gain. ...

Subsequent activities such as crushing, washing, screening and sorting of the mineral material in order to make the product of the mine or pit marketable are considered to be processing activities. ... You have indicated that it is your opinion that if a road contractor processes material and places the material on a road the activity would be considered to be construction. ... Accordingly, we agree with your conclusion that if a road contactor processes material and places the material on a road the activity would be considered to be construction. ...