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Effective splitting of Roth IRA where a Canadian contribution 1.12 If an individual resident in Canada makes a contribution to their Roth IRA or a contribution is made on their behalf (Canadian Contribution), part of the Roth IRA will cease to be considered a pension. ... The first part continues to be considered a pension and remains exempt from taxation in Canada (if an Election had been filed). The second part ceases to be considered a pension and becomes subject to Canadian taxation. 1.14 A Canadian Contribution does not include a contribution made before 2009, or a rollover contribution from another Roth IRA or a Roth 401(k) arrangement. ...

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) 1.10 The most important factor to be considered in determining whether an individual leaving Canada remains resident in Canada for tax purposes is whether the individual maintains residential ties with Canada while abroad…. 1.12 Where an individual who leaves Canada keeps a dwelling place in Canada (whether owned or leased), available for his or her occupation, that dwelling place will be considered to be a significant residential tie with Canada during the individual's stay abroad. ...

If it is, the income or a loss from the activities is generally considered to be from a business and will be treated as such for income tax purposes. 1.21 The following factors are relevant to determining whether farm activities are carried out in a commercial or business-like manner: the gross revenue and income or losses generated by the farm in the past; the extent and type of activity compared to farming businesses of a similar kind, size and location. If the size of the operation or property is too small to make a profit, the activity would not generally be considered to be carried out in a commercial or business-like manner. ...

[A] person is beneficially interested in a trust if they have any right to receive any of the income or capital of the trust as a beneficiary of a trust either directly from the trust or indirectly through one or more trusts or partnerships. 2.14 In the context of registered plans, this means that a controlling individual who holds units of an investment trust in their registered plan would be considered to be a beneficiary of that investment trust. ... This would be the case where an individual holds a sufficient number of rights such that they would not be considered to be dealing at arm’s length with the underlying corporation, partnership or trust either as a factual matter or, in the case of a corporation, because the application of subparagraph 251(5)(b)(i) results in the individual being treated as having control of the corporation and thus related to the corporation. ...

Decide whether the conditions of the working relationship represent the status that the parties have chosen and that they are consistent with the definitions of the Civil Code of Québec. 1.13 In applying these criteria, it is the complete interaction between the worker and the payer that must be considered. In the common law, no single criterion determines whether an individual is an employee or a self-employed person; all the criteria are considered relevant. ...

This anti-avoidance provision will apply where a new corporation would be considered not to deal at arm's length with a predecessor corporation as a result of a transaction or series of transactions the principal purpose of which may reasonably be considered to have been to cause subsection 1100(2.2) or 1102(14) of the Regulations to apply to a given amalgamation. ...

Even if a person inhabits a housing unit only for a short period of time in the year, this is sufficient for the housing unit to be considered ordinarily inhabited in the year by that person.... ... Land exceeding 1/2 hectare 2.34 Land in excess of one-half hectare may be considered necessary where the size or character of a housing unit together with its location on the lot make such excess land essential to its use and enjoyment as a residence, or where the location of a housing unit requires such excess land in order to provide its occupants with access to and from public roads. ...