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Reporting of news, preparation of copy of advertisements, photographs and art work, and editing are also considered qualified activities provided that the physical activities of manufacturing a newspaper are carried out by the taxpayer. ... However, the outcome and rationale for the decisions made in these cases is considered by the Department to have restricted application to similar businesses in the oil well service industry. ... The basis for the position in paragraph 44 of IT-145R allowing most of the activities performed in connection with publication of a newspaper to be considered qualifying activities arose as a result of the Department losing the court case The St. ...

With respect to the first issue, it is your view that, because of the operation of subsection 88(4), NewTarget will be considered to be the same corporation as, and a continuation of, Target for the purpose of the reference to "subsidiary" in subparagraph 88(1)(c.4)(iii). ... With respect to the second issue, it is your view that, because of the operation of subsection 88(4), NewTarget will be considered to be the same corporation as, and a continuation of, Subco2 for the purpose of determining whether the Keep Assets and the Sell Assets were capital property owned by NewTarget at the time that Parent last acquired control of NewTarget. ... With respect to the first issue, it is your view that, because of the operation of subsection 88(4), NewTarget2 will be considered to be the same corporation as, and a continuation of, Target for the purpose of the reference to "subsidiary" in subparagraph 88(1)(c.4)(iii). ...

You have asked us whether LP2 would be considered to be a foreign affiliate of Canco for the purposes of the definition of "excluded property" in subsection 95(1). ... In determining whether LP2 is a foreign affiliate of Canco, LP1 is considered to have a direct equity percentage of 15% in LP2. ... Accordingly, Canco would not be considered to be related to LP1 for the purposes of determining whether LP2 is a foreign affiliate of Canco for the purposes of the definition of "excluded property". ...

Reg. 227/2009 ("NI 45-106"), is considered to be document similar to a prospectus for purposes of the public corporation election. ... In Technical Interpretation no. 9529225, the CRA described as follows what type of document should be considered as a "similar document" for the purposes of paragraph 4803(2)(a) of the Regulations. ... Consequently, we are of the view that to be considered a "similar document" for the purposes of paragraph 4803(2)(a) of the Regulations, a document should contain information similar to, and be prepared for the same purpose as, a prospectus or registration statement. ...

What must be considered in an analysis under subparagraph (7)(b) of Article IV of the Canada-U.S. ... In making an analysis under subparagraph (7)(b) of Article IV of the Treaty, what needs to be considered is the U.S. tax treatment of the amount of income (in this case, the distribution from the Trust) paid to the Non-resident Beneficiary when the Trust is fiscally transparent for U.S. tax purposes and when it is not. ... As mentioned above, for the purposes of an analysis under subparagraph (7)(b) of Article IV of the Treaty, what needs to be considered is how the distribution from the Trust paid to the Non-resident Beneficiary is treated when the Trust is considered fiscally transparent compared to when it is not fiscally transparent under the taxation laws of the U.S. ...

They will be ignored for purposes of determining the types of property of DC until the resolution of the objections; h) The balance of any unamortized amounts relating to the DC Plan shown on DC’s balance sheet for accounting purposes (as described in the second part of Paragraph 29.3) will not be considered property. 16. ... For greater certainty, any contingent obligations of DC will not be considered a liability. For the purpose of Paragraph 73, the amounts described in Subparagraph 73 j) will be considered a true legal liability which is capable of quantification, and not a contingent liability. ...

A for the 1 Class B preferred share would be considered fair market value paid for such share at the time of issuance. ... A would be considered to have disposed of a right, interest or right to dividends in Opco to Mrs. ... A is considered to have disposed of a right, interest or right to dividends in Opco to Mrs. ...

YOUR QUESTION You have asked us whether the reimbursement of the legal fees would be considered to be a reimbursement of "personal" expenses of the Employee and therefore are properly characterized as a taxable benefit or, alternatively, whether the reimbursement would be considered a reimbursement of expenses incurred by reason of employment and would not be characterized as a taxable benefit to the Employee. ... " In our view reimbursements of personal expenses by an employer are considered to be "benefits of any kind whatever" received by an employee by virtue of office or employment and therefore these amounts have to be included in income under paragraph 6(1)(a). ... Whether specific legal fees reimbursed by an employer would be considered to be an employee's personal expenses is a question of fact that can only be determined after a complete review of the circumstances in each case. ...

It is possible in certain circumstances that a person might be considered wholly dependent notwithstanding that he or she had income. ... A person may be considered the child of an individual under the extended meaning of child found in the Income Tax Act. ... Thus, as one of the requirements would not be met, such a person would not be considered the child of the individual under the extended meaning of child. ...

The CRA’s position had been that contingent liabilities and accounting reserves, such as future employee benefits and pension obligations, reduce the safe income that can reasonably be considered to contribute to the capital gain on a share. ... The audit practices that a CRA auditor typically carries out to verify the calculation of safe income that can reasonably be considered to contribute to the capital gain on a share are similar to audit steps on any other audit issue. ... That includes a verification of the portion of the safe income that can reasonably be considered to contribute to the capital gain on each share of the corporation in any given year. ...