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It is implicit from the existence and wording of paragraph 1 of Article XXI of the Convention that exempt charitable entities would normally be considered as residents for the purposes of the Convention and thereby qualify for treaty entitlement. ...

The notice of the shareholders' meeting at which the proposal is to be considered must set out the terms of the proposal; if authorized by a special resolution of the shareholders, the company may apply to the Minister of Finance (the "Minister") for letters patent dissolving the company. ...

Generally, acquisition will be considered to have taken place when title passes or, if title remains with the vendor as security for the unpaid balance, when all the incidents of title pass. ...

The requirements concerning the application and granting of approved status are as follows: 1.To be considered an "approved" association for the purposes of section 37 of the Act, the association must receive written approval from this Department. 2.In order for an organization to become an approved association it must meet the criteria of a non-profit organization and be able to demonstrate that it is able to carry out SR&ED in Canada on an ongoing basis. ...

If the investment income of the affiliate is considered Fapi, then it would be included for this period as well. ...

Roy Attention: XXXXXXXXXX February 23, 1995 Dear Sir: Re: Retiring Allowance This is in reply to your letter of December 20, 1994 in which you requested our opinion on whether years of service with another employer which participates in the local authorities pension plan can be considered for purposes of calculating the number of years when determining the eligible portion of a retiring allowance transferred to a registered retirement savings plan ("RRSP"). ...

You have put forth the argument that the wife should be considered to own the cottage for the years in question as a result of her beneficial ownership therein so that the cottage meets the definition of a principal residence for the purposes of the principal residence exemption. ...

If the sale price is legally receivable on first closing, this amount will be considered income for tax purposes as at that date. ...

If the receipt relates to the loss of an income-producing asset, it will be considered to be a capital receipt; on the other hand, if the compensation was received for the failure to receive a sum of money that would have been an income item if it had been received, the compensation will likely be an income receipt. ...

Where an insurer that qualifies for the exemption under paragraph 149(1)(t) pays out dividends, such dividends would normally be considered "taxable dividends" as defined in subsection 89(1) of the Act. ...