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A dyke is generally considered a structure and the costs of which are included in Class 1(q), 10(g) or 41(b)(i) of Schedule II in the Regulations. ... This paper is going to examine various factors to be considered in making such a determination. ... However, based upon the above-noted jurisprudence, the pre-production dyke construction expenditures would generally be considered on account of capital. ...

Position: Our position is that a genuine loan to a trust would not in and by itself be considered to result in the application of subsection 75(2) of the Act if the loan is outside and independent of the terms of the trust. ... Loans made by the settlor Our position is that a genuine loan to a trust would not in and by itself be considered to result in the application of subsection 75(2) of the Act if the loan is outside and independent of the terms of the trust. ... Where the beneficiaries under a trust are named in the trust indenture and cannot be modified (i.e., the person from whom the property was received by the trust cannot select additional beneficiaries after the creation of the trust), subparagraph 75(2)(a)(ii) is generally not considered applicable. ...

Where a subsidiary is acting as agent for its parent, the parent would have ownership rights to the SR&ED and would be considered to have incurred the SR&ED expenditure made by the subsidiary. ... Where a subsidiary is acting as agent for its parent, the parent would have ownership rights to the SR&ED expenditure and would be considered to have incurred the SR&ED expenditure made by the subsidiary...." Applying this to the example described above, if CANCO is acting as agent for USCO then USCO would have ownership rights to the SR&ED expenditure and USCO would be considered to have incurred the SR&ED expenditure. ...

By this we mean, if a particular visit to Canada is considered part of the person's sojourning time in Canada, any part days included in the visit would be considered whole days. However a person is not automatically considered to be sojourning for every day (or part day) that the person is present in Canada. ... In such a case we suggest that the entire visit would be considered sojourning, notwithstanding that the visit may include a flight or other employment related duties. ...

XXXXXXXXXX (4) Trade account receivables, which are held to meet current cash flow or current working capital requirements, generally would be considered used in an active business. ... Generally, a debt will not be considered bad unless the creditor has exhausted all legal means of collecting it, or the debtor has become insolvent and has no means of paying it. ... Trade account receivables, which are held to meet current cash flow or current working capital requirements, are generally considered used in an active business. ...

Principal Issues: Whether the land owned by a taxpayer is considered to be "qualified farm property"? ... Some of the criteria which should be considered in making this determination are set out in Interpretation Bulletin IT-322R. Rental income would not be considered to be part of a farming business. ...

Principal Issues: Whether the land owned by a taxpayer is considered to be "qualified farm property"? ... 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. ...

A dyke is generally considered a structure and the costs of which are included in Class 1(q), 10(g) or 41(b)(i) of Schedule II in the Regulations. ... This paper is going to examine various factors to be considered in making such a determination. ... However, based upon the above-noted jurisprudence, the pre-production dyke construction expenditures would generally be considered on account of capital. ...

Lump sum cash payments received by individuals other than self-employed individuals, would be considered other income by virtue of subparagraph 56(1)(a)(vi) of the Act. ... Our Comments Taxation of FCP In our view, FCP payments received by self-employed individuals, considered to have been earning income from business, would be included in the computation of business income by virtue of section 9 and/or 28 of the Income Tax Act (the "Act"). ... In our view, the lump sum cash payments received by individuals who were previously employed in the fishing industry, would be considered other income by virtue of subparagraph 56(1)(a)(vi) of the Act. ...

In our view, the early retirement payments received by individuals other than self-employed individuals, would be considered other income by virtue of subparagraph 56(1)(a)(vi) of the Act. ... Adjustment Measures In our view, payments under this measures would be considered payments under EI Part II programming and would be taxable as other income under paragraph 56(1)(r) of the Act. ... Term Job Creation In our view, all payments made under this measure received by individuals, whether employees or self-employed individuals, would be considered other income by virtue of subparagraph 56(1)(a)(vi) of the Act. ...