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The term "likely" has been judicially considered to mean "more than possible, but, perhaps, less than probable" (Bennignton v. ... More generally, these reserves may be analogous to catastrophes, which have been considered by the CICA, in Financial Reporting for Property and Casualty Insurers, A Research Study, 1974. ... The branch and Head Office are one entity and the actions of the Head Office are considered those of the Branch. ...

A at January 31, 1990, is considered "earned income" for the purposes of a Registered Retirement Savings Plan (RRSP) contribution.  ... Thus the portion of the allocated income that can be considered to be from the partnership business during the period from February 1, 1989, to July 1, 1989, would be considered "earned income" for the purposes of a RRSP contribution, if Mr. ... We agree that if the residual interest has a negative adjusted cost base at January 31,1990, after the allocations, this will be considered a capital gain. ...

Such moneys could, however, be considered "Indian moneys" as defined in section 2 of the Indian Act in that the moneys are held by Her Majesty for the use and benefit of the incompetent Indian. ... If the CRF is located on the reserve the income would be considered to be earned on a reserve and would not be taxable. However, if the CRF is located off the reserve the income would be considered, to be earned away from the reserve and would be taxable. ...

As discussed in our telephone conversation of December 6, 1989 (19(1)/ Humenuk), you would like to know whether, in a situation such as that which you describe, the holding companies would be considered affiliates of the operating company and thus whether the amount received by the individuals would be considered as employment income rather than as a retiring allowance.  ... If this were the case the employee could not be considered to have retired from his office or employment. ... We caution that the above noted comments represent our considered opinion on the issues raised and are not binding on the Department. ...

The same would be the case for a trip from a branch to their home;- travel from one branch to another would also be considered to be for business purposes, as would travel between the employee's base office and a branch;- travel from the employee's home to the base office would be considered to be personal, and the same treatment would be given to travel from the employee's base office to home. ... These particular trips are not considered to be of a personal nature. 2. Whether an employee's place of work is to be considered a "regular place of work" is a question of fact that can only be determined on a case by case basis upon a review of all the individual's circumstances. ...

It should be noted that for purposes of the Act, life insurance corporations are considered to be public corporations. ... If the corporation is part of a group of related corporations, the combined services of their employees and the combined salaries and wages paid must be considered in making this determination. ... Due to the detail and complexity of the Regulations regarding these issues, the foregoing comments are meant only to provide an overview of the relevant provisions and under no circumstances are they to be considered to be either comprehensive or all inclusive. ...

You have also asked for our opinion on whether Highway 556 (Case #l) and Highway 6 (Case #2) referred to in your memorandum can be considered to be "ordinarily continuously usable" all-weather roads for the 1987 and 1988 taxation years. ... Based on the above, it is our view that Highway 6 may be considered an all-weather road for the 1987 taxation year but should not be considered an all-weather road for the 1988 taxation year as it was not ordinarily continuously usable in the 1988 taxation year. In addition, it appears that as the road will be closed to all traffic from September 7, 1989 to December 8, 1989 it should also not be considered an all-weather road for the 1989. taxation year. ...

In your opinion the portion of the Rescheduling Fee that can reasonably be considered to relate to the Credit Facility is deductible under paragraph 20(1)(e) of the Act. ... We agree with your opinion that the portion of the Rescheduling Fee that may reasonably be considered to relate to the Credit Facility is deductible under paragraph 20(1) (e) of the Act. In our opinion however the portion of the Rescheduling Fee that can reasonably be considered 24(1) 24(1) In our opinion paragraph 20(1)(f) of the Act is not applicable to the Debenture Fee but it may be considered an eligible capital expenditure within its meaning under paragraph 14(5)(b) of the Act and accordingly a deduction may be claimed under paragraph 20(1)(b) of the Act. ...

In determining whether a loan comes within the exemption provisions of subparagraph 15(2)(a)(ii) of the Act, it is our view that the term "dwelling for his habitation" includes only that portion of the land subject to and contiguous to the dwelling which can reasonably be considered to be required for the use and enjoyment of the dwelling. While the Department does not generally dispute the use and enjoyment of land which is less than 1/2 hectare, land in excess of 1/2 hectare will only be considered as part of the dwelling if it is established to be necessary for the use and enjoyment of that dwelling. ... You also asked us to confirm than an arrangement need not be in writing in order to be bona fide and that an arrangement which is evidenced by way of letter between employer and employee or a corporate policy applicable to all such loans would be considered to be a bona fide arrangement. ...

Whether an employee can be considered to regularly report for work at any location is a question of fact with consideration given to all relevant facts such as duration of time the site is reported to in relation to other work sites, the wording of the employment agreement if there is one and so forth. Those tree planters that report to several job sites in the course of the year, that cannot be considered to regularly or ordinarily report to any one place of business of the employer, can clearly meet the "in different places" clause of subparagraph 8(1)(h)(i) of the Act. ... Those tree planters that are considered to ordinarily carry on their duties of employment in different places may not be considered to ordinarily report for work at any particular employer establishment or municipality and hence may be precluded from a meals deduction by virtue of subsection 8(4) of the Act. ...