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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. ...

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. ...

In the process of revising the bulletin with respect to other issues the decision was made to delete the statement because it was considered to be a contentious issue and that its presence might spark debate on the subject. ... If the parking benefit were considered to be in relation to the use of an automobile then it would clearly be affected by the provisions of subparagraph 6(1)(a)(iii) of the Act. ... All of the above comments should be considered in determining the significance of the statements in the Report. 23 21(1)(b) We hope that our comments will be of some assistance. ...

An amount may be considered received by a taxpayer under circumstances other than when he has it physically in hand. ... It is also considered to be constructively received where the amount is credited to an account, on the taxpayer's behalf, to which he has relatively unrestricted access. ... However, since the individual's entitlement to current or prior year benefits is not determined until the application is received and approved no amount can be considered received in those prior years. ...

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. ...

As indicated therein, where there is a sole executor (executrix) and that executor has been and will continue to be resident in Canada until the affairs of the estate are settled, the estate will generally be considered to be resident in Canada. ... Paragraph 6 of IT-286R2 discusses this "paid or entitlement" question in the context of whether or not income of a testamentary trust is considered to be payable in the "executor's year" (i.e, the initial 12 month period commencing with the settlor's death). ... Where an executor requests a clearance certificate based on the return filed for the trust, the return will generally be considered to be the final return and the trust will be considered to have been wound-up during the executor's year, even where the actual distribution occurs shortly thereafter. ...

The Department's position as to the interpretation of the word "temporary" in this context is reflected in paragraph 9 of interpretation bulletin IT-91R3 which describes the general rule that employment for a period beyond two years would not normally be considered temporary. ... The two years is considered to be a reasonable guideline for employment that purports to be a temporary assignment. ... From your description of the employee's use of the automobile it is not clear whether he would meet this 90% test keeping in mind that travel such as between a temporary residence and his work place is considered personal in nature. ...

Reasons: Only work that is actually performed on a reserve should be considered when applying the Guidelines. Consistent with jurisprudence, it is the CRA’s longstanding position that time spent off-reserve preparing for work on a reserve and time spent travelling to and from a reserve is not considered time spent working on a reserve. ... In other words, it is our view that time spent preparing for work on a reserve and time spent travelling to and from a reserve is not considered time spent performing employment duties on a reserve. ...

If your son does not ordinarily reside, or intend to ordinarily reside, within twelve months after the end of the renovation period, with a qualified relation as described above, the property will not be considered an eligible dwelling, and the MHRTC cannot be claimed. If the property is considered an eligible dwelling, you must also consider whether the renovation would be considered a qualifying renovation. If the bathroom renovation is not undertaken to create a secondary unit in the dwelling to enable your son to live with a qualifying relation, then it will not be considered a qualifying renovation, and the MHRTC cannot be claimed. ...

., subsections 12(12) and 12(14)) on the basis that the disposition can reasonably be considered to have occurred due to the death of the taxpayer's parent. ... In a situation where one or more of the exceptions applies, the property is not considered a “flipped property” and subsections 12(12) to 12(14) will not apply. As noted, subparagraph (b)(i) provides an exception where a disposition of a housing unit “…can reasonably be considered to occur due to, or in anticipation of,….the death of the taxpayer or a person related to the taxpayer.” ...