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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.” ...

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. ...

Finally, in order for eligible moving expenses to be considered "as or on account of moving expenses incurred in respect of an eligible relocation", they must fall within the limitations in subsection 62(1) of the Act. ... Where it is determined that a taxpayer does not ordinarily reside at a new residence, the move to that residence would be considered temporary and would not be treated as a separate move. ... Where it is determined that the taxpayer ordinarily resided at House A, House B and House C, each move would be considered a separate move (one move to House B and a separate move to House C). ...

2) Is the bonus annuity, representing interest earned, considered pension income or investment income earned in Canada? ... Specifically, you wish to know: (1) is the guaranteed annuity of $XXXXXXXXXX taxable as income to the Canadian resident or is considered a return of capital? (2) Is the bonus annuity considered investment income or pension income? ...

2010 Ruling 2009-0352121R3- Status of 149(1)(l) entity created by a Charity Unedited CRA Tags 149(1)(l), 149.1(2)(a), 188.1(1)(b) Principal Issues: Two rulings: (1) Whether Newco will be considered to be organized and operated as a 149(1)(l) entity. (2) Whether the Charity will not be considered to be carrying on a business by virtue of the consignment sale arrangement. Position: Rulings given: (1) Newco will be considered to be organized as a 149(1)(l) entity. (2) The Charity will not be considered to be carrying on a business solely by virtue of the consignment sale arrangement. ... For purposes of paragraphs 149.1(2)(a) and 188.1(1)(b) of the Act the Charity will not be considered to be carrying on a business solely by virtue of the consignment sale arrangement described in paragraph 12. ...

Cash and cash equivalent are considered to be used principally in a business if their withdrawal would cause the destabilization of the financial aspect of the business. 3. ... The cash balances which accumulate and which are, thereafter, used in accordance with annual seasonal fluctuations of a permanent business will usually be considered used in a business, but a continuous balance which exceeds the reasonable working capital needs of a corporation will not usually be considered used to this end. 5. ... The CRA is also of the opinion that cash or cash equivalent which is only used to pay the current portion of long term debt is not usually considered to be used in a business. ...

Whether a property is considered to have been used in the course of carrying on the business of farming is dependent on when the property was last acquired by the individual. ... 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. ... Some of the criteria which should be considered in making this determination are set out in Interpretation Bulletin IT-322R. ...

Paragraph 37(8)(b) of the ITA states that SR&ED activities undertaken by a taxpayer that may lead to or facilitate an extension of the taxpayer's business, shall be considered related to the taxpayer's business. ... If USCo is Canco's only client and all income earned by Canco is from the SR&ED activities, then the SR&ED activities would be considered to be related to Canco's business. ... Ownership of rights in intellectual property or rights to use the SR&ED would be an important factor to be considered when ruling on this matter. ...