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General Background Your inquiry centers on whether certain activities would be considered an installation or engineering activity for purposes of clause 122.3(1)(b)(i)(B).  ... It is also our view that the above activities would generally not be considered engineering activities.   ...

Murphy (613) 957-8953 Attention: XXXXXXXXXX July 11, 1995 Dear Sirs: Re: XXXXXXXXXX This is in reply to your letter of March 30, 1995 wherein you enquired whether the above trust would be considered to be a flow-through entity as defined in (draft at the time of your letter) subsection 39.1(1) of the Income Tax Act. ... Therefore, in our opinion, as the Fund has "elected" to be treated as a partnership for tax purposes it would be considered to be a flow-through entity. ...

In IT-206R entitled Separate Businesses, subparagraph 4(c) states where the ownership of a corporation has changed, two operations will not normally be considered the same business if the first business ceases operation before the second operation begins. It goes on to comment on the factors that will be considered in determining whether a business ceases. ...

You state that you are aware that amounts received in respect of a fellowship are not generally considered earned income for RRSP purposes. ... However, if a fellowship award is considered a research grant that is included in income under paragraph 56(1)(o) of the Act, the fellowship award would be included in earned income for RRSP purposes. ...

B have exactly the same features and can belong to separate classes under the corporate law applicable to the corporation (which we doubt), they will be considered to be separate classes. Otherwise, they would be considered to be of the same class. Note that if there were two series of shares in the class, the calculation of the paid-up capital under subparagraph 89(1)(b)(iii) of the Act should be done by substituting the words “series of the class” for “class” under subsection 248(6) of the Act. ...

If an employee's employment is terminated by retirement or by elimination of the position, and an amount is paid by the employer for one of the reasons set out in the definition of "retiring allowance" in subsection 248(1) of the Income Tax Act, that amount will be considered a retiring allowance. If, however, at the time of the termination a new employment has been arranged or offered, the employee will be considered to have neither retired nor to have lost an employment and, thus, the amount will not be a "retiring allowance" within the meaning of that term as provided in the Act. ...

In order for a corporation to be considered a resident of the United States under the Convention, it must be liable to tax therein on its world income as are corporations incorporated pursuant to the laws of the United States. ... Consequently, we are of the view that an "S" corporation is to be considered a resident of the United States for purposes of the Convention. ...

Your question It has come to your attention that, if the vehicles were to have company advertising on 3 sides, then the expense can be considered an advertising expense and therefore, not a taxable benefit. ... As noted in paragraph 5 of Interpretation Bulletin IT-63R5, travel between an employee's place of work and home, even if the employee may have to return to work after regular duty hours, is considered personal. ...

Health care premiums that are paid by an individual and that are reimbursed by an employer, former employer or superannuation find are taxable in the hands of the individual, because these payments are considered to be a reimbursement of personal expenditures of the individual. As with other expenditures that are the personal liability of an individual, when an employer pays these premiums or reimburses an employee for such payments, the employee is considered to have received a taxable employment benefit according to existing income tax legislation. ...

Under paragraph (e) of the definition of "taxable life insurance policy" in subsection 211(1), a life insurance policy that is at that time an RCA is excluded from being considered a taxable life insurance policy for the purposes of Part XII.3. Will a life insurance policy owned by an RCA trust be exempted from being considered a taxable life insurance policy under paragraph (e) of the definition of "taxable life insurance policy" in subsection 211(1)? ...