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Application of GAAR should be considered. Reasons: The legislation CLHIA ROUNDTABLE- MAY 2009 Question #5 Criss-Cross Buy Sell Arrangement and Policyholder Tax Facts Two shareholders (A and B) of a corporation enter into a buy-sell agreement where the criss-cross purchase method is used. ... Subsection 148(7) of the Act further provides that B will be considered to have acquired the policy for an amount equal to that same "value". ... The possible application of section 245 of the Act should also be considered. 2009-031667 Alison Campbell May 1, 2009 ...

Judge Lucien Cardin upheld that none of the changes made could be considered as separate or abortive attempts to borrow money or to issue shares. ... In that situation, the expense will normally be considered to be incurred in the course of the issuance." Thus, in the given situation, if the Year 2 and the Year 3 transactions are considered to be substituted for the original one, the expenses incurred in Year 1 will be considered to be incurred in the course of the issuance. ...

You have not advised whether the employees are permitted to use the vehicles for personal travel other than from home to work and back or whether the vehicles are considered to be "automobiles" for income tax purposes. ... The use of an employer-provided motor vehicle by an employee to travel between his or her home and a regular place of employment is considered personal notwithstanding that the vehicle may be required because the employee is "on-call" for emergency purposes. However, where the employee proceeds directly from home to a point of call other than the employer's place of business to which the employee regularly reports or returns home from such a point, the use of the vehicle is considered employment-related. ...

From XXXXXXXXXX to XXXXXXXXXX Brother A lived in House A and considered it to be his principal residence. From XXXXXXXXXX to XXXXXXXXXX Brother B lived in House B and considered it to be his principal residence. ... Excess land may be considered necessary if the location of the housing unit requires the excess land in order to provide its occupants with access to and from public roads. ...

Consequently, the property can be considered to have been used in the course of carrying on the business of farming if the requirements of either subparagraph (a)(vi) or (a)(vii) of the definition are met. ... Some of the criteria which should be considered in making this determination are set out in Interpretation Bulletin IT-322R. ... Further, that paragraph indicates the requirement is considered to have been met when the person is actively engaged in the management and/or day-to-day activities of the farming business. ...

The amounts paid for education would generally be considered scholarships or bursaries and included in income under paragraph 56(1)(n). ... Assistance for Health Care Needs Such a Grant would be considered a SAP but, on the basis that it is paid in respect of medical expenses, would not have to be reported in income. ... Assistance for Acquiring Work Tools Such a Grant would be considered a SAP but, on the basis that it is paid as a lump sum (i.e., not part of a series of payments), would not have to be reported in income. ...

In general terms, travel between an employee's home and regular place of employment is considered personal. It will always be a question fact whether a particular work location is considered a regular place of employment. However, any location at or from which the employee regularly reports for work or performs the duties of employment is generally considered a regular place of employment. ...

(iii) Travel between home and work is considered personal. However, per para. 5 of IT-63R5, travel from home to a point of call will be considered employment-related. ... These particular trips are not considered to be of a personal nature." Scenario 1 Travel between the office and home before and after the conference would ordinarily be considered personal. ... If the employee were required to report to the first facility to receive instructions or work assignments before proceeding to the second facility, then it is likely that the trip to the second facility would be considered employment-related. ...

(iii) Travel between home and work is considered personal. However, per para. 5 of IT-63R5, travel from home to a point of call will be considered employment-related. ... These particular trips are not considered to be of a personal nature." Scenario 1 Travel between the office and home before and after the conference would ordinarily be considered personal. ... If the employee were required to report to the first facility to receive instructions or work assignments before proceeding to the second facility, then it is likely that the trip to the second facility would be considered employment-related. ...

The more an individual is involved in the management and/or current activities of the business, the more likely it is that the individual will be considered to participate in the business on a regular, continuous and substantial basis. ... Paragraph 120.4(1.1)(a) is considered as a “bright-line deeming rule” that is intended to eliminate some of the uncertainty inherent in the “regular, continuous and substantial basis” test described above. ... Based on the above, there are certain situations where the average work commitment could be considered as being “regular, continuous and substantial” even if the bright-line deeming rule is not met. ...