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What is considered to be the "property of the bankrupt in the trustee's possession" for the purposes of paragraph 128(1)(e) of the Income Tax Act. 4. ... In the situation described in the inquiry, what property of Canco's would be considered "the property of the bankrupt in the trustee's possession"? ...

For example, maintaining reasonable operating reserves or bank accounts required for ordinary operations will generally be considered to be an activity undertaken to meet the not-for-profit objectives of an organization. ... Income that is not incidental will usually be considered to be income of the unit owners, if this is appropriate under the relevant provincial law. ...

One of the factors to be considered includes the expected useful life of the website. ... In addition, if a particular expenditure is considered to be a capital expenditure that is not a depreciable property it might be an "eligible capital expenditure" as defined in subsection 14(5) of the Act. ...

In order for a transfer to be considered voluntary, there must be no obligation to make such a transfer. ... If the class "B" shareholders considered that the lawyer's work had also benefited them, any payment made by the class "B" shareholders to the lawyer would be taxable income. ...

A prize can be considered to be an award to a particular person selected from a group of potential recipients and given for something that is accomplished, attained or carried out successfully. ... For example, a prize to the winner of a video contest for students studying digital communications would likely be considered a prize for achievement in a field of endeavour ordinarily carried on by the taxpayer for the purposes of subparagraph 56(1)(n)(i) of the Act. ...

As non-resident corporations are not otherwise excluded from the application of subsection 15(1.1), whenever a corporation has paid a stock dividend, regardless of whether that corporation is a resident or non-resident of Canada, subsection 15(1.1) must be considered. ... Both Canco and ForHoldco were considered specified shareholders of ForOpco, and as a result, it was reasonable to conclude that the purpose of the stock dividend was to significantly alter the interest of a specified shareholder of the corporation. ...

For purposes of an employer computing its eligible salaries and wages payable for purposes of claiming the apprenticeship job creation tax credit, whether an employee who is an apprentice in a federally regulated trade such as an aircraft maintenance engineer licensed by Transport Canada can be considered an "eligible apprentice" within the meaning of subsection 127(9) of the Income Tax Act. 2. ... Although an aircraft maintenance engineer is a trade that is federally regulated and as such, can be considered to be a trade in respect of Canada, it is not a trade "prescribed" in respect of Canada. ...

Where a product provides for a death benefit or constitutes an annuity arrangement, it could be considered a life insurance product for purposes of the Act. ... Transfer of Policy to Taxpayer The transfer of an interest in a life insurance policy between individuals is generally considered a "disposition" and therefore a taxable event. ...

Paragraphs 5 and 6 of IT-91R4 provide comments on whether employment duties at a special work site will be considered temporary. ... It is the view of the CRA that the duties to be performed by an employee at a particular work location will not be considered to be of a temporary nature where the employer requires the duties to be performed on an ongoing basis, even though the particular employee's contract is for a short term. ...

You state that the goodwill has not been purchased by the partnership, has a nil tax basis and the elected amount being considered for the goodwill is $1. ... The assumption of the partnership debt by Corp would be considered non-share consideration received by the partnership. ...