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In any event, a request cannot be considered for a ruling when the transactions are completed or where the issues involved are primarily questions of fact. ...

We have considered the additional information that you provided, and our position on the tax treatment of employer-paid permanent residence authorization fees remains unchanged. ...

We have previously considered the wording of typical wills that provides for the trustees exercising their discretion in the timing of the realization of the assets of an estate and concluded that such wording is not indicative of an intention to create a trust. ...

The courts have established that such payments cannot be considered to be "support" for purposes of the Act, which means that there is no deduction available to the individual pursuant to paragraph 60(b) of the Act. ...

Where the purchase price for the trees on the woodlot is dependent on the use of or production from a property, other than an agricultural property, the amount received will be considered income from business or property pursuant to paragraph 12(1)(g) of the Act. ...

However, as stated in paragraph 16 of IT-305R4, the renting of real estate at market value or the lending of money on commercial terms will generally not be considered to result in someone receiving or otherwise obtaining the use of trust property. ...

In any event, a request cannot be considered for a ruling when the transactions are completed or where the issues involved are primarily questions of fact. ...

It is our view that the Norwegian resident would not be considered to be carrying on activities in Canada in connection with the exploration or exploitation of the seabed and subsoil and their natural resources in cases where the only activity of the Norwegian resident is to rent moveable property used in offshore activities in Canada. ...

A corporation's securities of the same class are generally considered to be "identical properties". ...

Further, since a unit of a mutual fund trust represents a beneficiary's interest in the assets of the trust, it would not generally be considered to be a type of indebtedness as described in the definition of specified debt obligation. ...