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Where an amount paid in the course of a landlord's property rental business to obtain the lead or anchor tenant(s) for a project yields a benefit of an enduring nature to the landlord, it is considered to be an eligible capital expenditure. A lead or anchor tenant is so characterized on the basis of such factors as square metres (feet) leased, the duration of the lease and its financial or marketing importance to the project. c) current expenditure: An amount paid in the course of a landlord's property rental business to obtain a non-anchor tenant is considered to be on income account. An amount paid to a lead or anchor tenant is also considered to be on income account where the payment does not yield an enduring benefit. ...

"The person... is unknown" In the case of stock brokers dealing with unclaimed dividends, the owner is considered unknown. ... The problem in this case is that the chartered bank would probably not be considered to have "received" any amount in respect of crediting the account. ... We also have doubts whether the lump sum payments to the Bank of Canada can be considered to be "in respect of interest". ...

Reasons: Subsection 118.05(2) of the Act requires the individual's interests (or for civil law, right) in the qualifying home to be registered in accordance with the land registration system or other similar system applicable where it is located, for the property to be considered as a qualifying home for purposes of claiming HBTC. ... An individual is considered to be a first-time home buyer for this purpose if, during the four calendar years preceding the year of acquisition, neither the individual, nor the individual's spouse or common-law partner, owned a home that was occupied, generally, by the individual or the individual's spouse or common-law partner. ... As you have confirmed that the mobile home in question is not registered with the XXXXXXXXXX land registration system, it is not likely to be considered as a qualifying home pursuant to subsection 118.05(2) of the Act. ...

The amount included as a taxable benefit is considered to be an amount paid for the purposes of the child care expense deduction. ... Whether an amount is paid for the purpose of any particular deduction or personal tax credit must consider the specific applicable legislation. b) The CRA has not previously issued a technical interpretation as to whether a benefit received qua shareholder would be considered to be an amount paid for the purpose of the child care expense deduction. Similarly, this question would have to be considered individually for any particular deduction or credit. ...

21 May 2015 External T.I. 2015-0576831E5- "eligible property"- lessee's interest in a lease CRA Tags 85(1.1) Principal Issues: Whether a lessee's interest in a lease for equipment would be considered eligible property pursuant to subsection 85(1.1). ... Reasons: Although a lessee's interest in a lease would generally be considered property, it is a question of fact whether a particular interest under a lease contract would be on account of capital. ... Gibbons May 21, 2015 Dear XXXXXXXXXX: We are writing in response to your letter of March 11, 2015, regarding whether a lessee's interest in a lease for equipment would be considered "eligible property" pursuant to the definition of this term in subsection 85(1.1) of the Income Tax Act (the "Act"). ...

Under Article IV(6) of the Convention, the Canadian source business profits of the LLC are considered to be derived by the US-resident individuals. ... Treaty benefits under Article X(6) of the Convention may be claimed by an LLC on behalf of its members with respect to an amount of profit attributable to a Canadian branch only if the amount is considered to be derived, pursuant to Article IV(6), by a US-resident company that is a "qualifying person" or by a US-resident company that is entitled, with respect to the amount, to the benefits of the Treaty pursuant to Article XXIX A(3). In the example set out above, the earnings of the LLC are considered to be derived by US-resident individuals. ...

The spouses are not considered living separate and apart and only one can claim the credit. ... You enquire whether the Individuals, who are billed under separate account numbers and have a partition divider between their beds, can be considered involuntarily separated for purposes of claiming the Credit. ... Therefore, the Individuals are not considered living separate and apart, regardless of their financial billing or other arrangements, for purposes of claiming the Credit. ...

29 October 2007 External T.I. 2007-0225901E5- Clearly Marked Emergency-Response Vehicles Unedited CRA Tags 248(1) 6(1)(a) Principal Issues: Whether a taxable benefit results in respect of the personal use of an employer-provided motor vehicle that is not considered an automobile because it is a clearly marked emergency-response vehicle? ... In this regard, use of an employer-provided motor vehicle by an employee to travel between his or her home and regular place of employment is considered personal. ... However, where the employee proceeds directly from home to a point of call other than the employer's place of business to which the employee regularly reports or returns home from such a point, use of the vehicle is not considered personal. ...

Railroad Retirement Tax Act are considered to be non-business income taxes for the purposes of the foreign tax credit. Position: Tier 1 railroad retirement taxes are considered to be non-business income taxes but Tier 2 railroad retirement taxes are not. ... Railroad Retirement Tax Act are considered to be non-business income taxes for the purposes of the foreign tax credit. ...

XXXXXXXXXX The Agency's general position as set out in that letter indicates that an employer is considered to have control over the tips where the employer is able to direct how the tips will be paid. ... Tips that are included in the employer's business income are also considered to be under the employer's control. Credit card tips directed at a server where the tip amount is not included with the rest of the bill payment as business income of the employer, or subject to a sharing arrangement, would not be considered to be under the control of the employer and therefore would not be subject to payroll withholding. ...