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If the answer to this question is sufficiently clear, then the following question should be considered. 2. ... Under this program, it is likely that at least a portion of the Assistance paid would be considered POD for the property. ... When compensation is received for the loss or destruction of capital property, the amount of the compensation is considered to be proceeds of disposition received on the disposition of that property, whereas any compensation received for the loss or destruction of inventory or for loss of profits is considered to be income from carrying on a business or income from property, as appropriate. ...

It consists of XXXXXXXXXX None of these changes which are meant to deal with the changes in law are relevant with respect to the rulings and opinions given which are considered routine. ... XXXXXXXXXX 962523 Attention: XXXXXXXXXX XXXXXXXXXX, 1996 Re: XXXXXXXXXX Advance Income Tax Ruling This is in reply to your request of XXXXXXXXXX as revised by your facsimile transmission of XXXXXXXXXX, for an advance income tax ruling on behalf of: XXXXXXXXXX You advise that to the best of your knowledge and that of XXXXXXXXXX and the General Partners: (a)none of the matters considered in the requested Ruling are being considered by a district tax services office or a taxation centre of Revenue Canada, Customs, Excise and Taxation ("Revenue Canada") in connection with a tax return already filed; and (b)none of the matters considered in the requested Ruling is under objection or appeal. ... (b)For greater certainty, if draft section 143.2 of the Act is enacted as proposed in the Notice of Ways and Means Motion tabled on June 20, 1996, by the Minister of Finance, and if any Investor has limited-recourse amounts that can reasonably be considered to relate to the acquisition of Units, it is our opinion that: (i) draft subsection 143.2(6) of the Act (not subparagraph 53(2)(c)(i.3)) would apply to reduce that Investor's cost of the Units, and (ii) the expenditures made by XXXXXXXXXX would also be considered to relate to those limited-recourse amounts and would be reduced by the total of such limited-recourse amounts. ...

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. ...

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. ...

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. ...

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. ...

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. ...

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. ...

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.” ...