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14 July 2004 Internal T.I. 2004-0072241I7 - Provincial ITC & 12(1)(x)

With respect to the second criteria, you have asked when an amount is considered to reduce the tax payable for a taxation year. ... Also you have asked, when an amount is considered to be paid, if it allows for an increase in a tax refund. 3. ... In either case, the amount would not be considered received in 2002. It would likely be considered received in the 2003 taxation year, and would therefore be reported in that year. ...

27 November 2018 CTF Roundtable Q. 9, 2018-0779981C6 - TOSI–Excluded Amount - Non-Related Bus. Exception

The dividend will be considered an “excluded amount” since it was not derived from a related business in respect of the individuals for the year. ... A in Year 2 would not constitute an “excluded amount” and would, absent any other consideration, be considered split income of Mr. ... A from Serviceco in Year 2 will be considered to be derived directly or indirectly from a related business. ...

1 November 1990 Internal T.I. 900479 F - Manufacturing & Processing Profits Deduction

In addition, even though the information contained in the books could be considered to have been processed, since that information was subject to copyright it could not sold. ... As previously mentioned, even after the decision in McGraw-Hill was issued, these activities are still considered to be the provision of a service rather than the M&P of goods for sale. The second type of situation considered was an arrangement similar to the comprehensive agency contract entered into by Cabana. ...

7 November 1990 Income Tax Severed Letter - Manufacturing & Processing Profits Deduction

In addition, even though the information contained in the books could be considered to have been processed, since that information was subject to copyright it could not sold. ... As previously mentioned, even after the decision in McGraw-Hill was issued, these activities are still considered to be the provision of a service rather than the M&P of goods for sale. The second type of situation considered was an arrangement similar to the comprehensive agency contract entered into by Cabana. ...

11 July 1991 Internal T.I. 903359 F - Offshore Activities Article (Tax Treaties)

What would be considered "activities" for purposes of paragraph 2 of Article XXVIIA of the U.K. ... What would be considered to be "offshore" for the purposes of this Article? ... This would not apply to those vessels considered to be operating in international traffic as Article 8 is considered to exempt such income from taxation in Canada. ...

7 July 1991 Income Tax Severed Letter - Offshore activities tax treatment — Canada-U.K. tax treaty and Canada-Netherlands tax treaty

What would be considered "activities" for purposes of paragraph 2 of Article XXVIIA of the U.K. ... What would be considered to be "offshore" for the purposes of this Article? ... This would not apply to those vessels considered to be operating in international traffic as Article 8 is considered to exempt such income from taxation in Canada. ...

Alberta Power (2000) Ltd. v. The Queen, 2009 DTC 1514, 2009 TCC 412

Implied repeal is sometimes considered a method of actual repeal rather than a rule of paramountcy. ... Paragraph 12(1)(x) was introduced to clarify the tax treatment of tenant inducements which in some cases the courts had considered to be tax-free ... Also, the phrase “may not reasonably consider” was considered in Canada Trustco v. ...

Lipson v. Canada, 2009 DTC 5528, 2009 SCC 1, [2009] 1 SCR 3

However, the entire series of transactions should be considered in order to determine whether the individual transactions within the series abuse one or more of the provisions of the Act. ... The Minister concedes that the $562,500 mortgage loan is properly considered to be a refinancing of the $562,500 stock purchase loan. ... At para. 46 of his reasons, LeBel J. also says that the “interpretation and application” of s. 74.5(11) should be considered in another case. ...

Guindon v. Canada, 2015 SCC 41, [2015] 3 SCR 3

The Court has even done so of its own motion, as we shall see. [22] The test for whether new issues should be considered is a stringent one. ... Thus, this Court may answer a constitutional question that was not even considered in the courts below. ... [para. 49] [116] The importance of a full evidentiary record when resolving constitutional questions was considered in MacKay v. ...

CanUtilities Holdings Ltd v. The Queen, 2003 TCC 193

It seems likely then that a structure sensitive to the requirements of public shareholders, as well as to the Majority Shareholders, must have already been considered by the Appellants' advisers. [71] Mr. ... Baxter testified that three different structures were considered as a means to purchase the ATCOR shares. ... The Queen, 2000 DTC 2428 at 2432 as a requirement for finding a series for tax purposes at common law, a requirement of a common subject matter or motivation emerges from all authorities considered. ...

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