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As an example, where a Canadian company borrows from a U.S. partnership, whose partners are residents of the U.S. and Germany, any interest paid on the loan will, for tax treaty purposes, be considered to be received by the individual partners. ...

It was considered impractical in this instance to draw distinctions between whether the handicap is the habit itself, or if it is those disabilities that are caused by the habit. ...

Although we are of the view that the income is also properly taxable in Canada, there is some uncertainty as to whether a) the amount should be treated on a net or gross basis, b) whether the "looking through" principle can be used with respect to the underlying components of the income, and c) whether the tax paid by the trustees can be considered to have been paid by the beneficiary for the purposes of granting a foreign tax credit. ...

As such a transfer could not be considered to be a payment described in paragraph 2(a), Article XVIII of the Canada-U.S. ...

It is the Department's view, notwithstanding the fact that the shares of Company B held by Company A were disposed of by Company A at 2:00 p.m. on June 1, 1989, that in the particular situation outlined above, Company A would be considered to have relinquished control of Company B immediately before the time that Company C was deemed to have acquired control of Company B. ...

We understand your question to be whether or not the policy which covers the manager can be considered to be part of the same plan as that which covers the other employees, even though they are covered by a different policy. ...

For the payment to be taxable in Canada it must be considered to be "remuneration for labour or for services" within the meaning of those words in Article XI of the Canada-Netherlands Income Tax Convention (1957) (the "Convention"). ...

An amount equal to the fair market value of the note would be considered to be a contribution of capital and may be added to the adjusted cost base of any shares of FA-2 owned by FA-1 if the conditions set out in paragraph 53(1)(c) of the Act are met. ...

In your example, the foreign currency funds on deposit would not be considered disposed of until they are converted into another currency or are used to purchase a negotiable instrument or some other asset. ...

Therefore, for the purpose of computing the partner's income (including the application of section 95 of the Act), the partnership would be considered to own the shares of and to control the non-resident corporation. ...