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S4-F15-C1- Manufacturing and Processing-- summary under Paragraph (h) Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Manufacturing or Processing- Paragraph (h) Electricity for own use not excluded 1.17 The production or processing of electrical energy or steam used directly or indirectly by taxpayers in their own manufacturing or processing activities is generally considered to be eligible for the M&P credit. ...

In some industries, the use of the company's assets in manufacturing or processing activities may also be considered where the use of labour does not accurately reflect the principal activities of the corporation. ...

S4-F15-C1- Manufacturing and Processing-- summary under Rental Cost Summary Under Tax Topics- Income Tax Regulations- Regulation 5202- Rental Cost Royalties included 1.30 Royalty payments are considered to qualify as rental costs under paragraph (b) of the definition of cost of capital in section 5202 of the Regulations. ...

However, when such dividend is subject to the application of subsection 55(2), it is considered that a deduction under subsection 112(1) was not permitted in respect of that dividend and there is no denied increase in cost under subparagraph 53(1)(b)(ii). ...

Review of operations over more than a year 1.15 In… determining a corporation's principal business for a particular tax year, only the business operations in that year should be considered. ... Assimilation of management functions 1.16 The management and administrative functions which are necessary to the conduct of the business operations referred to in [s. 66(15)] are considered to be an integral part of those operations. ...

For example, if there is a series of transactions occurring on the same day, which is followed by an amalgamation on that same day for which no time is specified, the amalgamation will be considered to occur at the time specified in the arrangement insofar as the series occurs logically. ... …Generally, a transaction would be considered to occur outside the normal course of business if, for example, the transaction is described in a closing agenda or other document describing the sequential order of transactions which must occur in order to carry out the amalgamation of the predecessor corporations. 1.20 Where a corporation amalgamates with a target corporation in the form of a horizontal amalgamation such that the former shareholders of the corporation acquire control of the new corporation, subparagraph 256(7)(b)(ii) will deem control of the target corporation to have been acquired immediately before the horizontal amalgamation. ...

A debt is considered bad for the purpose of section 50 when the whole amount is uncollectible.... ...

In other words, only de jure control is considered. ...

In this respect, two businesses will be considered to be similar if they both fall within the same one of the following categories: merchandising- retailing and wholesaling; farming; fishing; forestry and forest products; extractive industries, including refining; financial services; communications; transportation; construction, including subcontracting; and manufacturing and processing. 1.42 With regard to the categories referred to in ¶1.41, where a business falls into more than one, a similar business will be one that falls into any one of these categories in which the business operates. ...

However, if a trust is established by contributions from two or more unrelated persons and those unrelated persons are beneficiaries of the trust, their respective interests in the trust would be considered to have been acquired for consideration. ...