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Would partnership A be considered to have acquired a specified animal from a person with whom it was not dealing at arm's length? ... Would partnership C be considered to have acquired a specified animal from a person with whom it was not dealing at arm's length? ... Would partnership G be considered to have acquired a specified animal from a person with whom it was not dealing at arms length. ...

Will a passive rental property be considered to be used in the business of a sole proprietor? ... Each of the corporations would be considered to have disposed of their partnership interests at the fair market value thereof. ... Where the transaction is considered to be at arm's length the provisions of subsection 1100(2.2) of the Regulations may be available. ...

Is a video tape considered to be certified for the purpose of the definition of certified production, after Part A or Part 8 of the certification form has been filed and accepted by the M.O.C? ... In other words, even though Part 8 of the form was never completed and the conditions therein not satisfied, the certificate could still legally be considered a valid certificate. ... If an amount invested in an uncompleted and uncertified film or video tape is not eligible to be included in class 10(s), it could be considered capital property of the investor. ...

It is our view that the ECE tuition reimbursement would be considered a bursary, given that it helps students pursue their education. ... In the present case, unless a student’s tuition fees are paid for, or reimbursed by their employer, it is our view that PT students in a recognized ECE program are likely to be considered PT qualifying students. ... In the affirmative, it seems unlikely that students would be considered qualifying students during such terms, and their scholarship exemption is likely to be limited to the basic scholarship exemption (up to a maximum of $500). ...

As a general rule, items that retain a value independent of the renovation will not be considered integral to the eligible dwelling. ... Conversely, items that are affixed to the dwelling and cannot be moved without altering or damaging the dwelling- or without altering their value or usefulness- would generally be considered integral to the dwelling. ... However, adding a bathroom to the basement is unlikely to be considered a qualifying renovation if it is done solely for convenience. ...

The answer to this depends on whether the Bare Trust is considered to dispose of the Bond when the Bond matures and the proceeds are paid to the Bare Trust. ... We understand that the Bare Trust considered herein is resident in Canada, has no Part I tax payable for the year, and has not realized a capital gain in the year. ... The result is that the termination of the Bare Trust would not be considered to result in a disposition of the property held by the Bare Trust. ...

2.In what situations will the taxpayer be considered to have de jure control of the Liechtenstein Stiftung or a Liechtenstein Anstalt? ... In general, your primary position is that the "N Anstalt" should be considered a corporation for Canadian Income Tax purposes and be considered a controlled foreign affiliate of the taxpayer and subject to FAPI. ... As such, in our opinion, the entity would be considered a controlled foreign affiliate of the taxpayer. ...

Entities that are subject to tax, but with respect to which tax may be relieved under an integrated system, are not considered "fiscally transparent". ... A trust that is not disregarded for Canadian tax purposes would generally not be considered to be an entity that is "fiscally transparent". ... A trust that is not disregarded for Canadian tax purposes would generally not be considered to be an entity that is "fiscally transparent". ...

It is your view that such an array would be considered a separate and distinct asset and would not be considered to be an integral or component part of the building. ... A property will not be considered to have been used for any purpose where it is new at the time that it is acquired. ... However, a property that is used regularly by the vendor for demonstration purposes is considered to have been used by the vendor. ...

Forestry workers may be considered to travel away from their employer's place of business or in different places in certain circumstances. ... As discussed above, whether an employee can be considered to regularly report for work at any particular location is a question of fact. ... As discussed above, where an employer sets up a remote forest camp, it would generally be considered to be one of the employer's places of business. ...