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As mentioned in paragraph 14 of Interpretation Bulletin IT-91R4, a work location will be considered to be remote if the nearest established community with a population of 1,000 or more is no closer than 80 kilometres by the most direct route normally travelled in the circumstances. The term "established community", as stated in paragraph 15 of the aforementioned bulletin, is considered to mean a body of people who reside in the same locality and who are permanently settled in that location. ... The two years is considered to be a reasonable guideline for employment that purports to be a temporary assignment. ...

Interest income is generated off reserve and is considered to be earned in the economic mainstream and therefore not tax exempt. ... Under the Act, an estate whether testate or intestate, is considered to be a trust and is subject to all the taxation rules which apply to trusts. ... As such income may be generated off the reserve or by non-Indians, it would be considered to be earned in the normal economic mainstream and, accordingly, not considered personal property situated on a reserve. ...

The rental property would be considered real or immovable property situated in Canada and depreciable capital property for purposes of the Act. ... Prior to the time when the estate administration is complete, the executors are generally considered to hold legal and beneficial ownership of the estate property and the estate is still considered to be in existence. It is a question of mixed fact and law as to when beneficial ownership of the estate property is considered to pass to the beneficiaries. ...

The evidence also established that the trip was predominantly of a business nature and consequently the benefit was considered not taxable. ... The value is considered to be a benefit received by virtue of his employment. ... As mentioned previously, where each individual is to be assessed a taxable benefit that individual's particular circumstances should be considered. ...

The evidence also established that the trip was predominantly of a business nature and consequently the benefit was considered not taxable. ... The value is considered to be a benefit received by virtue of his employment. ... As mentioned previously, where each individual is to be assessed a taxable benefit that individual's particular circumstances should be considered. ...

The conveyor belt used to transport the raw material form the primary crusher to the secondary crusher will not be considered to be used in a processing takes place is not considered an eligible activity (per paragraph 28 of IT-145R).  ... The decision reached in the former case, that assets which were permanently affixed to concrete pads and supports were considered structures referred to in class 3, appears to be the reason that the current wording in class 8(a) was created.  ... M.N.R., 58 DTC 316, the courts considered the concept of movable equipment.  ...

That is, whether the secondary unit (for instance, a basement suite or laneway home) and the primary residence are considered one housing unit of the taxpayer. ... A taxpayer that constructs a secondary unit that is a self-contained housing unit according to the requirements of the MHRTC would generally be considered to have two separate housing units. ... Accordingly, a taxpayer that constructs a secondary unit that is a self-contained housing unit according to the requirements of the MHRTC would generally be considered to have two separate housing units. ...

T-SLIP The CI payments are considered farm support payments and a T-Slip will be required. ... T-SLIPS The research grants are not considered farm support payments. ... T-SLIPS The payment is not considered a farm support payment and T- Slips will not be required. ...

For the purposes of Interpretation Bulletin IT-92R2, can Canco be considered a primary contractor or subcontractor? RESPONSE #1 Yes, for the purpose of IT-92R2, Canco can be considered a prime contractor or subcontractor (i.e., we assume that installing the turbine and compressor is a part of the construction of a building, road, dam, bridge or similar structure, and that title to such turbine and compressor vests in a person other than Canco as they are installed). ...

In our opinion the filing of an agreement pursuant to paragraph 78(1)(b) of the Act in respect of an unpaid amount owing by a Canadian resident debtor to a non-resident creditor residing in a country with which Canada does not have a tax treaty would not in and of itself result in the non-resident creditor being considered to carry on business in Canada. The opinion expressed herein is not an advance income tax ruling and, in accordance with paragraph 21 of information Circular No. 70-6R2 dated September 28, 1990, is not considered binding on the Department. ...