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.), an insurance corporation that carries on business in Canada, including one described in paragraph 149(1)(t) of the Act, is considered a "financial institution" pursuant to paragraph (b) of that definition in subsection 181(1) of the Act. ... Section 142.5 of the Act generally requires a taxpayer that is a financial institution to annually recognize the appreciation or reduction in value of securities that are considered "mark-to-market property" as defined in subsection 142.2(1) of the Act. ...

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, procedures to treat PCOS would generally be considered to have a medical or reconstructive purpose. ...

In Interpretation Bulletin IT-339R2, Meaning of private health services plan [1988 and subsequent taxation years], the Canada Revenue Agency has set out the requirements that must be met in order for a plan to be considered a PHSP. ... Please refer to IT-339R2 for further information on the other requirements that must be met in order for a plan to be considered a PHSP. ...

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, procedures to treat PCOS would generally be considered to have a medical or reconstructive purpose. ...

CLHIA Roundtable- May 2011 Question 3- IFRS and Life Insurers a) Term Certain Annuities Under IFRS, term certain annuities with no mortality uncertainty are considered investment contracts and recorded as investment contract liabilities rather than insurance contracts, which are recorded as actuarial liabilities. ... Where accounting adjustments as a result of conversion from GAAP to IFRS are made to retained earnings, such adjustments should, in our view, be considered in determining taxable income in the first year in which the taxpayer uses IFRS. ...

If the vacation is taken prior to the commencement, or after the completion of the contract, it will not be considered as part of the contract in assessing whether the contract lasted the requisite period of more than 6 consecutive months. ... Paragraph 3 of IT-497R4 states that the "all or substantially all" test is considered to be met if 90% of the employment duties are performed outside Canada. ...

Royalties, which are akin to rental payments, have invariably been considered as income since they are either based on the degree of use of the right or on the duration of the use, while a lump sum payment for the absolute transfer of a right, without regard to the use to be made of it, is of its nature considered a capital payment, although it may of course be taxable as income in the hands of the recipient if it is part of that taxpayer's regular business. ...

Reasons: The settlement or award is considered "compensation for property injuriously affected" and would give rise to a capital gain by virtue of paragraph (e) of the definition of "proceeds of disposition" in section 54 of the Act. ... In our view, the award from the lawsuit settlement will give rise to a capital gain as it is considered "compensation for property injuriously affected", by virtue of paragraph (e) of the definition of "proceeds of disposition" in section 54 of the Act. ...

If the social committee is not funded and controlled by the employer, a prize won via lottery from the social committee is considered to be a windfall. ... When a recipient donates the gift to the Committee and the Committee then awards it to another employee, where all employees have a chance to win the gift, the employee in receipt of the gift from the Committee will not be considered to have received a taxable benefit from the employer. ...

If there are elements which suggest that the activities could be considered a hobby or other personal pursuit (as may often be the case in respect of artistic undertakings), the venture will be considered a source of income for the purposes of the Act only if it is undertaken in a sufficiently commercial manner. ...