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In the case of commodity futures or commodities, the Courts have long established that trading in commodity futures or commodities is either a business or considered to be an adventure in the nature of trade, such that related gains and losses would be on income account. ...

I can also tell you that all the comments made at the various meetings and all the written submissions were considered in drafting the guidelines. ...

The central management and control of an organization is considered to be exercised by the group that performs the function of a Board of Directors of the organization and may be exercised in a place other than the principal administrative office of the organization. ...

It is the current use made of the borrowed funds in a particular year rather than the initial use of the funds which must be considered in determining whether the interest paid or payable with respect to the borrowed funds is deductible in a particular year. ...

Property is defined in subsection 248(1) of the Income Tax Act (the "Act") as: `"Property" means property of any kind whatever whether real or personal or corporeal or incorporeal and, without restricting the generality of the foregoing, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, (c) a timber resource property, and (d) the work in progress of a business that is a profession;' Paragraph 1 of IT-297R2 states that a "gift" includes a "gift in kind" and paragraph 3 describes the types of property that may and may not be considered gifts in kind. ...

As stated in paragraph 1 of the bulletin, the transfer of a policy will only be considered a gift for the purposes of subsection 118.1(1) or paragraph 110.1(1)(a) of the Act where no right, privilege, benefit or material advantage accrues to the donor or to a person designated by the donor. ...

It is our view that amounts received in lieu of earnings during this period of leave from employment would be considered employment income and therefore would not be a retiring allowance. ...

An insurance contract which provides survivor income benefits is considered to be a life insurance policy the proceeds of which are payable as an annuity. ...

As indicated in paragraph 21 of Information Circular 70-6R2 dated September 28, 1990, a request for a written opinion on a completed transaction is generally considered by the taxpayer's local district office. ...

Under Guideline 2, where the employment duties of Indians are performed entirely off a reserve, the employment income earned will be tax-exempt if the employer is resident on a reserve and the Indian lives on a reserve, except where it can reasonably be considered that one of the main purposes for the existence of the employment relationship is to establish a connecting factor between the income in question and a reserve. ...