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This is in contrast to the situation where an employer might compensate an employee for a reduced loss which is considered a taxable benefit. ... The reimbursement of the employee's loss on the sale of his residence was considered to be non-taxable on the basis that it was incurred by reason of his employment. ... Where the employer reimburses the employee to compensate for the reduced gain, such a reimbursement is considered a taxable benefit. ...

At other times, Finco has funds that are not immediately required for the purchase of receivables and on which Finco earns interest income (the "Interest"). 7) Finco regularly pays dividends to Canco out of any surplus funds in its bank account that are not reasonably required for the purchase of new receivables from Manco. 8) Subject to the application of paragraph 95(2)(a) of the Income Tax Act (the "Act") the income earned by Finco from its factoring activity would be considered income from property. ... The funds in the bank account of Finco may be considered at risk in the business of Manco where the permanent removal of such funds would have a destabilizing effect on the business of Manco. ... In any case, since the question of whether a portion of the funds in the bank account of Finco could reasonably be considered at risk in the business of Manco is entirely a question of fact, we can provide no further comment. ...

The Department has accepted that certain joint ventures created under the Co-operative JV Law would be considered corporations for the purposes of the Act. ... The following attributes none of which in and by themselves would in our view decide the matter are generally considered to favour the conclusion that the entity created would be viewed as a corporation for the purposes of the Act: A) The joint venture satisfies the conditions set out in Article 37 of the Civil Law Principles of the People's Republic of China to qualify as a legal person thereunder. ... Each owner of a beneficial interest in the joint venture would be considered to own a number of shares proportionate to his beneficial interest in the joint venture. ...

Where an organization asserts that it satisfies the residence requirement because it holds its board of directors meetings on reserve, it will generally be considered to satisfy the residence criteria where management and control over the organization is legitimately exercised during those meetings. In addition, the fact that the board of directors meetings may be held on different reserves would not, in and by itself, cause an organization not to be considered resident on a reserve. In our view, in a situation where the board of directors meets regularly on a reserve, albeit different reserves, and decisions are made at these meetings which direct an organization's operations, such an organization would generally be considered resident on a reserve. ...

Bank account transfers between corporations, related or otherwise, are considered as loans and advances. ... TD Bank, 17 O.R. (3d), 363 daily bank transfers from subsidiary corporations to a concentration account under a mirror accounting system were considered to be legally effective. ... It is our view that where the balance sheet of a corporation, prepared in accordance with GAAP, reflect the intercompany obligations that these obligations would be considered as loans and advances for purposes of subsections 181.2(3) and (4) of the Act. ...

Position: Basically it appears no as by entering into an annuity arrangement the foundation would be considered to have incurred a debt other than those allowed. ... These types of arrangements are considered to be annuities for the purpose of the Income Tax Act (the "Act"), therefore, they are subject to tax under the ordinary rules relating to annuities except in the very narrow circumstances as outlined in paragraph 3 of Interpretation Bulletin IT-111R, dated February 27, 1984. ... An undertaking to make annuity payments is considered to be a debt incurred by the charity which, in the case of a charitable foundation, is cause for the revocation of its registration. ...

Self-employed persons, considered to be earning income from business, in receipt of these payments, were required to report these payments as a business receipt in computing their business income for the year. ... In our view, such amounts received would not be considered to be income from an office or employment. Hence, a TAGS payment including the "TAGS Employment Bonus" that does not constitute self-employed earnings, will be considered other income by virtue of subparagraph 56(1)(a)(vi) of the Act. ...

., if funded only by employee contributions, is considered to be pension plan for the purposes of the Act and the eventual distributions from the Plan will be considered to be superannuation or pension benefits for purposes of the Act. ... Pursuant to the provisions of the Act distributions from an employee benefit plan, less the portion based on the terms of the Plan that can reasonably be considered to be a return of employee contributions to the Plan, will be included in employment income of the recipient for income tax purposes. ...

Bank account transfers between corporations, related or otherwise, are considered as loans and advances. ... TD Bank, 17 O.R. (3d), 363 daily bank transfers from subsidiary corporations to a concentration account under a mirror accounting system were considered to be legally effective. ... It is our view that where the balance sheet of a corporation, prepared in accordance with GAAP, reflect the intercompany obligations that these obligations would be considered as loans and advances for purposes of subsections 181.2(3) and (4) of the Act. ...

XXXXXXXXXX General Discussion This Directorate, in 1992, considered a similar type of business activity with regards to the M&P Deduction in response to a request from the Toronto District Office. ... At paragraph 43 of Interpretation Bulletin IT-145R it was established that the activities connected with the processing of film into prints and slides, negatives into prints and the enlarging of prints are considered to be activities which qualify for the M&P Deduction. It therefore follows that similar activities should also be considered "manufacturing or processing in Canada of goods for sale" as that term is used at subsection 125.1(3) of the Act. ...