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Reasons: T\P considered to have acquired and own property for purposes of Reg. 5202. ... It is our opinion that the taxpayer who is the lessee in a leasing arrangement and who makes an election under subsection 16.1(1) of the Act is considered to have acquired the property for the purposes of calculating "adjusted business income" and the determination of the "cost of capital", as those terms are defined in section 5202 of the Regulations. ...

Under Canadian tax law, any shares distributed in such a way to Canadian shareholders are considered to be paid as dividends, which are subject to Canadian tax. ... In this regard, Finance officials have considered requests for amendments to the Act to exempt Canadian shareholders from tax on spin-offs undertaken by foreign corporations, but have concluded that amendments are not appropriate. ...

Under Canadian tax law, any shares distributed in such a way to Canadian shareholders are considered to be paid as dividends, which are subject to Canadian tax. ... In this regard, Finance officials have considered requests for amendments to the Act to exempt Canadian shareholders from tax on spin-offs undertaken by foreign corporations, but have concluded that amendments are not appropriate. ...

It is your view that, notwithstanding that the agreement refers to the amounts as "interest", those amounts could not be considered as such because there is no money held by the vendor which "belongs to" or is "owed to" the purchaser. ... Generally, the resolution of the question would depend, among other things, on whether the advance payments could be considered to be progress billings or whether they are deposits against the settlement of the final purchase price. ...

Reasons: Shares distributed by a corporation to its shareholders on a pro-rata basis are considered as dividends for Canadian tax purposes. ... Accordingly, your request would have to be considered by that department. ...

As indicated in paragraph 2 of IT-365R2, the receipt of an amount in respect of general or special damages for personal injury is normally not considered to be taxable. In addition, as indicated in paragraphs 3 and 5 of IT-365R2, an award of damages in respect of personal injury that is payable to the claimant in periodic payments is not normally considered to be taxable in the circumstances described in paragraph 3 and 5 of IT-365R2. ...

As a guideline, the intangible benefit from those events costing up to $100 per person will be considered to be non-taxable. Ancillary costs, such as transportation home, may increase the amount considered reasonable. ...

The Children will not be considered to have received any proceeds of disposition for the purpose of subsection 107(1) of the Act as a result of the proposed transactions.” ... The Children will not be considered to have received any proceeds of disposition for the purposes of subsections 40(1) and 107(1) of the Act as a result of the proposed transactions.” ...

Reasons: Vacation pay does not meet the definition of retiring allowance in subsection 248(1) of the Act and it is considered income from employment for purposes of the Act. ... In our view the reasoning in Harel does not extend to unused vacation and the interpretation bulletin clearly states that a payment for accumulated vacation leave is considered to be ordinary remuneration and is included in the recipient's income in the year of receipt pursuant to subsection 5(1) or 6(3) of the Act. ...

") is considered to be resident in the U.S. for purposes of paragraph 1 of Article IV of the Canada-United States Income Tax Convention (the "Convention"). ... In our opinion, as long as our position regarding a S corporation being a person resident in the U.S. for the purpose of paragraph 1 of Article IV of the Convention remains unchanged, a QSSS would be considered a person resident in the U.S. for the same purpose. ...