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Further, at the 1994 CTF Conference, Revenue Canada Round Table at question 2, we examined IT-95R, paragraph 3 and the fact that where borrowed funds are used in the ordinary course of a taxpayer's business, any foreign exchange gain/loss is considered to be on income account. ... We stated that here are no specific criteria under which funds borrowed in a foreign currency would be considered to be fixed or permanent capital and each case must be reviewed and determined on its own facts. ...

Furthermore, the Agency will also generally agree that the shareholder will not be considered to have transferred property to or otherwise conferred a benefit on the children (or their trust) who subscribe for the new common shares. ... Her Majesty the Queen (2000 DTC 6047) the Federal Court of Appeal considered a situation where shares in a family-owned company were issued to trusts for children. ...

21 March 2011 External T.I. 2011-0395011E5- Deductibility of Ontario SAT Unedited CRA Tags 18 Principal Issues: Whether the Ontario Special Additional Tax on Life Insurance Corporations (SAT) is considered a capital tax and is therefore deductible in computing income for tax purposes. ... In the absence of a specific prohibition in the Income Tax Act to the contrary, provincial capital taxes have been considered to be expenditures incurred for the purpose of gaining or producing income from a business or property and therefore deductible in computing income for federal income tax purposes. ...

TEI would appreciate the CCRA's confirming that transitory shares redeemed in the course of an 85(1) transaction to which subsection 55(3) applies are not considered offside and, thus the CCRA will not apply paragraph 85(1)(b) to the transaction. ... CCRA Response We confirm that the demand note received by the Transferor on the redemption of shares described in the hypothetical situation set out in the question would not be considered to be non-share consideration received for the transferred assets for the purposes of paragraph 85(1)(b). ...

15 August 2012 External T.I. 2012-0438481E5- Change of Fiscal Period Year-End Unedited CRA Tags 249.1(7) Principal Issues: Whether changing a fiscal period year-end from February 28 to February 29 in a leap year would be considered a change to a fiscal period requiring the consent of the CRA. ... XXXXXXXXXX 2012-043848 Andrea Boyle, CGA August 15, 2012 Dear XXXXXXXXXX: Re: Change of Fiscal Period Year-End I am writing in reply to your email of March 1, 2012 in which you asked whether changing a fiscal period year-end from February 28 to February 29 in a leap year would be considered a change to a fiscal period requiring the consent of the CRA. ...

The words "(or the amount ultimately considered to be the agreed amount)" are added in paragraph (b) after the words "agreed amount" and before the words "referred to". 9- Paragraphs (a) and (b) of ruling Q are replaced by the following: (a) the amount included in A of the definition of the "cumulative eligible capital" in respect of Operating LP by virtue of the acquisition of the CCo Operating Assets (other than the CCo Provincial Operating Assets previously transferred) as described in paragraph 63 will be equal to 3/4 of the agreed amount (or the amount ultimately considered to be the agreed amount) referred to in Paragraph 63 in respect of the eligible capital property included in such CCo Operating Assets; (b) the amount included in paragraph (a) of E of the definition of the "cumulative eligible capital" in respect of Operating LP by virtue of the disposition of the DCo Amalco Non-Operating Assets as described in paragraph 63 will be equal to the fair market value of the eligible capital property included in such DCo Amalco Non-Operating Assets (3/4 of which will be included in amount E of the definition of "cumulative eligible capital"); and Notwithstanding the above-mentioned changes, we confirm that the rulings given in the Ruling, as amended above, will continue to be binding on the Canada Revenue Agency in the manner described therein. ...

13 July 2010 External T.I. 2010-0359251E5- Frankfurt Stock Exchange Unedited CRA Tags ss. 248(1) "designated stock exchange", s. 262 Principal Issues: Whether the Open Market segment of the Frankfurt Stock Exchange is considered to be a designated stock exchange for purposes of the Act? ... Under European law, the Regulated Market qualifies as an EU-regulated market and the Open Market is considered to be an exchange-regulated market. ...

In your inquiry you have asked for our comments on the view that the normal reassessment period with respect to the T1135 may be considered separate and distinct from the normal reassessment period of the return of income to which it relates. ... We have previously provided the view that an assessment under Part I of the Act for amounts assessable under subsection 216(1) is considered separate and distinct from an assessment of other sources of income taxable under Part I. ...