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You have specifically asked for additional information concerning the types of fertility-related procedures that will qualify as well as whether all procedures performed by a medical practitioner for the purpose of conceiving a child are considered eligible. ... As a result, the same expenses will be considered eligible for the METC for patients who have a medical condition preventing them from conceiving a child and for those who do not. ... For example, a request made in 2019 must relate to the 2009 or a later tax year to be considered. ...

., in 2009-0339951E5) that we will recognize treaty benefits under Article X(6) that are claimed by a fiscally transparent entity (such as LLC3) with respect to an amount of income or profit attributable to its Canadian permanent establishment only if the amount is considered to be derived, pursuant to Article IV(6), by a U.S. resident corporation that is a “qualifying person” under paragraph 2 of Article XXIX-A or is entitled, with respect to the amount, to the benefits of the Treaty pursuant to paragraph 3 or 6 of Article XXIX-A. Pursuant to Article IV(6), an amount of income, profit or gain shall be considered to be derived by a person resident in the U.S. if, under U.S. income tax laws, the person is considered to derive the amount through a fiscally transparent entity that is not a resident of Canada, and that, by reason of the entity being fiscally transparent under U.S. laws, the U.S. income tax treatment of the amount is the same as the U.S. income tax treatment would be had the person derived the amount directly (the “same tax treatment” condition). ... We understand that for U.S. income tax purposes, the Canadian Branch profits of LLC3 are considered to be derived by the first entity in the corporate chain which is not treated as a fiscally transparent entity for U.S. income tax purposes. ...

We were asked whether the transfer would be considered to take place at non-arm's length such that subsection 148(7) applies. ... All of the facts relevant to a particular situation would need to be considered before determining whether parties to the transaction were dealing at arm's length. ... Due to the changing nature of Corporation A’s business, employee B is no longer considered to be a key employee. ...

Therefore, where a “professional status” is only acknowledged in the regulations of a statute or in an organization’s bylaws, the “professional status” would not likely be considered “recognized by statute” for purposes of subparagraph 8(1)(i)(i) of the Act.” ... For example, a professional status would be considered “recognized by statute” where a statute requires that certain services be only performed by a member of a particular professional organization, even though the organization itself is not regulated by statute. ... However, it is our view that where a “professional status” is only acknowledged in an organization’s bylaws, the “professional status” would not likely be considered “recognized by statute” for purposes of subparagraph 8(1)(i)(i) of the Act. ...

The information thus provided cannot be considered a confirmation by the CRA that an entity qualifies for the CEWS or TWS. ... In addition, subsection 149(1.1) of the Act provides that for the purposes of determining the 100% and 90% ownership tests in paragraphs 149(1)(d) to (d.6) of the Act any right to acquire shares or capital of a corporation should be considered as though the right had been exercised. ... For the purposes of determining whether the 90% or 100% test is met, the non-government person would be considered to own 20% of the shares or capital. ...

Residence of the Employees is not a factor to be considered in Guideline 1. ... The central management and control of an organization is considered to be exercised by the group that performs the function of a board of directors. ... If the central management and control of the Employer is, in fact, exercised on the Reserve, the Employer will be considered to be resident on the Reserve and Guideline 2 will apply to exempt the employment income of the Employee in scenario 1 where the Employee resides on a reserve. ...

We considered the following hypothetical scenario: 1. All of the shares of CanCo are owned by a corporation resident in the United States (“USCo”); the common shares of USCo are publicly listed on a designated stock exchange. 2. ... Unless section 7 or one of the specific exceptions in the SDA definition applies, the RSU plan will generally be considered an SDA. ... A payment made to reimburse a related party for bona fide expenses incurred pursuant to a legal agreement in return for adequate consideration would not generally be considered a benefit for purposes of subsections 15(1) and 246(1) and, thus by extension, Part XIII tax. ...

Advances to and investments in subsidiary corporations by the parent company will generally be considered to be advances of working capital and are of a capital nature (K.J. ... Similarly, payments in respect of guarantees are generally considered to be expenditures of a capital nature, the deduction of which is prohibited by paragraph 18(1)(b) of the Act (The Queen v. ... We trust  that our foregoing comments are satisfactory and helpful. for DirectorFinancial Industries Division Rulings Directorate APPENDIX CASES CONSIDERED Morflot Freightliners Ltd. v. ...

We would agree that, in those situations in which there has been a permanent impairment in the value of the investment, any write down to reflect that reduced value would not be considered to be a reserve for the purpose of computing the capital of the corporation pursuant to paragraph 181.2(3)(b) of the Act. ... Any taxes payable with respect to a proposed reassessment of a prior taxation year would be included in the calculation of the capital of the corporation as the liability for those taxes would be considered to have arisen in that prior year and, consequently, would constitute an other indebtedness of the corporation which has been outstanding in excess of 365 days as contemplated by paragraph 181.2(3)(f) of the Act. ... In those circumstances in which the "netting of payables and receivables" constitutes a payment of the trade liability and is not simply an aggregation or combination of accounts for the purpose of financial statement presentation we would consider that only the net account balance at the end of the taxation year need be considered to determine if that net amount is to be included in the capital of the corporation. ...

If tax withholdings are to be considered, only the current year's estimated tax withholdings appear to be justified; the choice of the greater of the two years' tax withholdings appears to be arbitrary. 8. ... The Federal Sales Tax Credit and the Child Tax Credit are not considered- deductions (i.e. they are not "true" tax credits) in computing taxes payable. They are considered amounts of taxes paid by the taxpayer and therefore, their treatment should be the same as that accorded to amounts deducted at source. ...