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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. ...

Reasons: The mortgage would not be considered payable to the taxpayer after the transfer. ... " (Emphasis added) No portion of the POD in the form of the Mortgage would be considered payable to the Taxpayers after that time where the Mortgage is payable to the Trust and, therefore, no reserve would be available under subparagraph 40(1)(a)(iii) to the Taxpayers for the Mortgage transferred to the Trust. ...

29 April 2011 External T.I. 2011-0400731E5- Milk Quotas- Qualified farm Property Unedited CRA Tags 14(1), 14(5), 54, 110.6(1) Principal Issues: Are Milk Quotas considered Qualified Farm Property Position: Yes if the milk quota otherwise meets the conditions provided in the definition of Qualified farm Property in subsection 110.6(1) of the Act. ... In order for the quotas to be considered to be so used, they must meet one of two general farming-use tests set out in subsection 110.6(1.3) of the Act. ...

That paragraph states that "any excess of the members' condominium fees and contributions over the corporation's expenditures for the year is not considered to be income of the corporation. ... The other portion of the fees could be considered to be income. However, based on the unique nature of residential condominium corporations, the CRA is prepared to accept that Overages do not have to be treated as income for income tax purposes, which is consistent with the position described in IT-304R2. ...

Pursuant to paragraph 118.2(2)(a) of the Act, an amount is considered to qualify as a medical expense for the purposes of the METC if it is paid to a medical practitioner, dentist or nurse or a public or licensed private hospital in respect of medical or dental services. ... In our view, a weight-loss program would be considered a medical service when the program is offered to an individual for therapeutic or rehabilitative reasons. ...

The same situation is considered to exist where a building is rented piecemeal (e.g., an apartment block) and the tenants are provided with only those basic services which, by custom, have come to be regarded as an inherent part of that kind of property rental, e.g.: heat, water, elevator service, telephone in lobby, indoor or outdoor parking spaces, laundry room with equipment for tenants, maintenance of the building itself (including janitor and window washing service, repainting of apartments), maintenance of adjacent areas (including snow and garbage removal service) and maintenance of any appliances and furnishings provided in the rented accommodation. Essentially, the nature and extent of services provided for, or made available to, tenants must be considered in determining whether a particular operation is a leasing business. ...

Commuting time to and from work, and stand-by time if applicable, is not considered time spent completing duties of employment on a reserve. ... You have not indicated the nature of the business of the self-employed Indians, but in a situation where the Indian is providing casual XXXXXXXXXX work, the location where the work is performed would likely be considered the location of the income-earning activities. ...

However, the cost of the donated property could be considered a general business expense. ... A donation made by an individual may only be eligible for the charitable donation tax credit if the donation is considered to be a gift. ...

In particular, you wish to know whether the "principal business real estate corporation test" in paragraph 1100(12)(b) of the Regulations (hereinafter referred to as the "PBREC test") for partnerships to qualify for the exception in subsection 1100(12) should be applied on the basis that any business carried on by partnership is considered to be carried on by the corporate partners. ... Further, the position in the Previous Opinions is based on the legal principle established by the courts that a partner, whether that partner is a general partner or a limited partner, is considered to carry on the business of the partnership. ...

Earning profits to fund not-for-profit objectives is not considered to be itself a not-for-profit objective. ... 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. ...