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29 September 1993 Income Tax Severed Letter 9315766 - Producing v. Processing of Industrial Mineral

Ct.) in which the Exchequer Court considered whether an open-pit gypsum operation was a mine in the context of "income derived from the operation of a mine" for the purpose of the three year tax exemption available at that time. ... The Quarry operation is similar to the sand and gravel operation in the case of Nomad Sand and Gravel Limited in that they are both considered as stone quarries. ... Subsequent activities such as crushing, washing, screening and sorting of the mineral material in order to make the product of the mine or pit marketable are considered to be processing activities. ...

6 July 2001 External T.I. 2001-0081575 - GENERAL INFORMATION TAX EXEMPT ENTITIES

For the purposes of determining whether the 90% or 100% test is met, the non-government person would be considered to own 20% of the shares. ... It will be a question of fact to be determined with regard to the particular circumstances as to whether a corporation will be considered to be carrying on a trade or business and if it is, whether these activities will cause the corporation to be considered to not be operated exclusively for non-profit purposes. ... Generally, where a corporation or other type of organization has very broad objectives and carries on a number of activities, some of which would be considered charitable and some of which would not be considered charitable in nature, the organization would not qualify for registration under the Act. ...

20 November 2001 External T.I. 2001-0085365 - Transfer of Property by an Estate

The house would be considered as having been distributed to the Estate by the Deemed Trust in satisfaction of the Estate's income and capital interests in the Deemed Trust. ... As for the Estate, it would be considered as having disposed of its income and capital interests in the Deemed Trust. ... As for the Spouse, she would be considered to have disposed of her income and capital interests in the Deemed Trust. ...

2 July 2002 External T.I. 2002-0128305 - principal residence

Generally, an expenditure is considered to be of a capital nature when an enduring benefit ensues. ... Some of the criteria which should be considered in making this determination are set out in Interpretation Bulletin IT-322R. ... As indicated in paragraph 9 of IT-433R, the crop share received by a landlord in a sharecropping arrangement is considered to be rental income and not income from farming. ...

11 May 2000 External T.I. 2000-0020555 - MUNIC. CORP.-INDIAN BANDS

3) Can a Tribal Council be considered a municipality in Canada? Position: 1) No, 2) Yes 3) No position given. ... In our view, for an Indian band to be considered a municipality in Canada, it would have to demonstrate that it fits within the facts of the Otineka case. ... As discussed in our earlier meeting, the CCRA has not published an opinion on whether a Tribal Council, on its own, may be considered a municipality in Canada. ...

26 October 2022 Internal T.I. 2021-0915091I7 - SR&ED Prescribed Expenditures

Further, the materials claimed are considered to be expenditures of a current nature. ... Thus, inventory which is current in nature is also considered property. ... Since you indicate in your memorandum that the XXXXXXXXXX Machine is considered a current expenditure for SR&ED purposes that was acquired used, it is our view that subparagraph 2902(b)(ii) of the Regulations would apply and the property would be considered a prescribed expenditure. ...

18 April 2023 Internal T.I. 2020-0864031I7 - Application of subparagraph 95(2)(a)(i)

Pursuant to the test under clause 95(2)(a)(i)(A), can the income from property earned by FA5 Subco “reasonably be considered to be directly related” to the active business activities carried on by FA4? ... Paragraphs 3 of Archived IT-206R indicates some of the factors that can be considered in order to make that determination. ... The notes further indicate that “assets will be considered to be at risk in a business where the permanent removal of such assets would have a destabilizing effect on the business.” ...

Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40

It now falls to be considered whether the alternative is appropriate. ... The leading case which considered subsection 6(a) of the Income War Tax Act was Dominion Natural Gas Co. v. ... Third, I note that there is no evidence to suggest that child care expenses are considered business expenses by accountants. ...

Commission Scolaire Des Patriotes v. The Queen, docket 1999-1464-GST-G

As a successor to the caisse's rights, the vendor had to be considered one of the parties to whom the judgment applied. ... It is therefore possible to be considered the owner of property under the tax rule even if one is not the owner under the civil law rule. ... In theory, the case could be reopened if the parties did not agree on these matters, and I therefore seriously doubt that the 2001 decision could be considered a final judgment. ...

11 August 2015 External T.I. 2015-0580521E5 - Settlement amount for disability benefits

You and counsel for the former employee agree that the portion of the Payment for past disability benefits is taxable and considered a "qualifying amount" as that term is defined in section 110.2 of the Act. ... Whether a particular employer's arrangement is considered an IP, requires a finding of fact that can only be made on a case by case basis. ... Only if the answer to the first question is no and the answer to the second question is yes, will the amount received be considered a retiring allowance. ...

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