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The factors are derived from those considered by the Supreme Court of Canada in Johns-Manville Canada Inc. v. ... On balance, expenditures that are a capital cost of equipment, facilities and structures for XXXXXXXXXX will be considered capital. ... Costs incurred to XXXXXXXXXX are appropriately considered to fit into two categories; costs to XXXXXXXXXX. ...

The factors are derived from those considered by the Supreme Court of Canada in Johns-Manville Canada Inc. v. ... On balance, expenditures that are a capital cost of equipment, facilities and structures for XXXXXXXXXX will be considered capital. ... Costs incurred to XXXXXXXXXX are appropriately considered to fit into two categories; costs to XXXXXXXXXX. ...

Principal Issues: Is US tax paid by a Canadian-resident individual with respect to his limited partnership interest in a US limited partnership that carries on business in the US considered non-business-income tax and deductible under s.20(12) of the Income Tax Act ("ITA")? Position: No Reasons: Assuming that the US limited partnership is considered to be a partnership for Canadian tax purposes, all partners, including the limited partner, is considered to carry on the business of the partnership. ... Since the US partnership is earning business income, X is considered to be earning US business income.? ...

Generally, financial self-sacrifice or denial of material comfort is considered to exist where a member's pay scale is substantially less than that of an employee performing similar duties in a non-religious organization. ... Based on the information provided, the Organization does not appear to embody the 2nd, 3rd, 4th, or 5th characteristic, and would not be considered a religious order. Consequently, the Employee would not be considered a member of a religious order. ...

In the current situation described, the amount paid to the employee would not be considered a reimbursement because it is not for a specific expense incurred by the employee. ... An employee who reports to work at a particular site for an extended period of time will likely be considered to regularly report to work at such location. ... As well, travel directly from one work location to another work location is considered to be employment-related travel. ...

More specifically, you have asked for guidance in determining whether XXXXXXXXXX (Organization) would be considered a religious order for purposes of paragraph 8(1)(c) of the Income Tax Act (Act). ... It is our view that the 6th characteristic needs to be considered, but would not be the deciding factor in determining whether an organization is a religious order. ... Therefore the Organization would not be considered to be a religious order. ...

In your letter, you are inquiring whether a particular individual would be considered your adopted child on the basis of an “adoption in fact”. ... 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. ...

Generally, a real or immovable property is considered to be used principally in a farming business by an individual if its primary use (that is, more than 50% of its use) is in the operation of a farming business. ... Some of the criteria to be considered in making this determination are set out in paragraph 4 of Interpretation Bulletin IT-322, Farm Losses. However, as indicated in paragraph 9 of Interpretation Bulletin IT-433R, Farming or Fishing- Use of Cash Method, the crop share received by a landlord in a sharecropping arrangement is generally considered to be rental income and not income from farming. ...