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With respect to the questions posed in 1, above, the Department takes the view that, unless the note is accepted as absolute payment as discussed in paragraph 2(b) of IT-436R an ordinary promissory note is considered to be a promise to pay and not payment of the remuneration owing.  ...

For example, subsection 110.6(7) of the Act may apply, depending on the facts of a particular situation, to deny a capital gains deduction claimed by a shareholder who is an individual in respect of the capital gain realized as a result of the application of paragraph 69(1)(b) of the Act because the corporation could be considered to have acquired its own shares for consideration that is significantly less than their fair market value at the time of acquisition, notwithstanding that the shareholder is deemed by paragraph 69(1)(b) to have disposed of his shares for proceeds of disposition equal to their fair market value. ...

It seems to us that, while paragraph 96(1)(f) of the Act does provide that in computing a partner's income the amount of income of the partnership from a source and the location of such source are to be considered that of the partner, this rule deals only with sources that are specifically enumerated in the Act.  ...

At present, the premiums for the accident and sickness policy are paid by the employer and are not considered to be benefits from employment in the hands of the employee pursuant to paragraph 6(1)(a) of the Income Tax Act (the "Act").  ...

Some questions that come to mind that bear on this issue are outlined below: 24(1) In conclusion, it is not necessary for a person to control or be in a position to control a partnership before he can be considered to be dealing non-arm's length with that partnership. ...

Educational leave or an educational grant paid by an employer to an employee is considered to be received in respect of, in the course or, or by virtue of the employee's office or employment and is included in income from an office or employment by virtue of paragraph 6(l)(a) of the Income Tax Act. ...

You have considered the definition of "fiscal period" at subsection 248(1) of the Act and of "taxation year', at subsection 249(1) of the Act, however, and you are of the opinion that the fiscal period selected 24(1) to file in Canada is acceptable. ...

On the assumption that the value of the consideration for the use of the cars supplied by the manufacturer is the annual cost of leasing a similar vehicles by A Co, that value would be considered as "amounts that may be reasonably regarded as having been payable by the employer to a lessor... ...

Neither efforts to purchase a business, nor the earning of interest income would be considered an active business carried on by the corporation.  ...

Paragraph 11 in particular sets out some of the factors to be considered in ascertaining whether security transactions should be on account of income.  ...