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Where the plan is not considered to be a PHSP within the meaning of subsection 248(1) of the Act, the fees are not an eligible medical expense for purposes of paragraph 118.2(2)(q) of the Act. ... Where the plan is considered to be a PHSP within the meaning of subsection 248(1) of the Act, the fees for a private health plan may be an eligible medical expense under paragraph 118.2(2)(q) of the Act. ... The expenditures must satisfy all of the conditions listed above to be considered eligible medical expenses under paragraph 118.2(2)(o) of the Act. ...

You have considered a hypothetical scenario whereby an individual resident in Italy receives periodic CPP and OAS benefit payments. ... Both the CPP and OAS are normally considered pensions for purposes of Canada’s tax treaties. ... CPP payments Where an individual resident in Italy receives CPP payments, those payments are generally considered pension income that arises in Canada. ...

Generally, if the principal purpose of the business is to derive income from property, the business could be considered a SIB. ... To be considered an active business, the activity should first qualify as a business. ... It should be noted that the "principal purpose" of a corporation must be determined annually after all the facts relating to the business (or businesses) carried on by that corporation in that year have been considered and analyzed. ...

If the withdrawal of the property would have a decidedly destabilizing effect on the corporate operations, the property would generally be considered to be used in the course of carrying on a business. ... Generally, an asset is considered to be used principally (i.e., more than 50%) in an active business if its primary or main use is in that business. ...

In particular, you asked whether the production or processing of fuel could be considered to be the manufacturing or processing of a good for sale in the context of the AITC. ... (footnote 5) The Act does not otherwise specify what is considered to be manufacturing or processing goods for sale or lease in the context of the AITC. ... Based on the foregoing, in our view the production or processing of a fuel could be considered to be the manufacturing or processing of a good for sale for purposes of the AITC, depending on the particular circumstances. ...

Where a foreign entity is considered to be a corporation for the purposes of the Act but ownership in the entity is not divided into units entitled shares, can an ownership interest in such an entity be considered to be shares in the capital stock of that entity for the purposes of the Act. 3. ... For purposes of the Act: (i) Finco will be considered a corporation; (ii) the ownership interests in Finco will be considered shares of Finco; (iii) Pubco's equity percentage in respect of Finco will be 100%; (iv) Finco will be a foreign affiliate and a controlled foreign affiliate of Pubco; (v) Pubco will have a qualifying interest in respect of Finco and will be related to Finco; and (vi) distributions of Finco's profit to its equity holder(s) will be considered dividends. ... For purposes of the Act: (i) Forco1 will be considered a corporation; (ii) the ownership interests in Forco1 will be considered shares of Forco1; (iii) Pubco's equity percentage in respect of Forco1 will be 100%; (iv) Forco1 will be a foreign affiliate and a controlled foreign affiliate of Pubco; (v) Pubco will have a qualifying interest in respect of Forco1 and will be related to Forco1; and (vi) distributions of Forco1's profit to its equity holder(s) will be considered dividends. ...