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Although it is too early to confirm anything yet, rest assured, all possible solutions are being considered. ... Re (a), Deltona considered the formation by amalgamation of a corporation to be its “incorporation.” ... The non-resident lessor is considered to be in the business of supplying tangible personal property by way of lease. ...

It is considered to be one of the hallmarks indicative of a genuine intergenerational business transfer. ... The Bare Trust would also be considered to be a trust for the purposes of paragraph (k) of the definition of disposition. ... So in the situation described in Part A of the question, although a disposition of the bond may well be considered to have occurred on the maturity of the bond, this is not considered to be a disposition by the Bare Trust. ...

A corporation that is considered a loan corporation for purposes of the Income Tax Act would also be considered a “loan corporation” for purposes of the draft SLFI Regulations. ... Will the “New Lessor’s” supplies be considered to have been made outside of Canada? ... CRA Comments A partnership is considered to be a person for GST/HST purposes. ...

In Québec, it has been determined that a call option is considered to be IPP that relates to real property. ... X, it does not appear that such free supplies would be considered to further the making of taxable supplies for consideration. ... As a result, it is unclear why the application of subsection 141.01(2) of the ETA would need to be considered. ...

Where an individual is considered to reside in Canada and another country, treaties must be taken into account, and the tie-breaker rules must be considered, which are cascading tests that must be applied in sequence. ... Stays would have to be considered. Again, if we get to the habitual abode, the other elements of the individual’s residence and of the centre of vital interests would not have been determinative, so stays would have to be considered, and the nature of the activities of the individual in a given country would be considered as well, to determine whether the individual usually lives in that state or not compared to the other. ... The court considered a matter that is essential to the CRA’s ongoing efforts to protect Canada’s tax-base and the integrity of tax treaties. ...

All factors that may affect the value of any unit in the building must also be considered. ... Canada, considered how to determine whether or not there is income from a source for the purpose of section 9. ... Similarly, the more an individual's involvement is integral to the success of the business, the more it would be considered important. ...

CRA has considered cash pooling in the context of s. 15(2) and similar principles will apply here. ... How much of the loan funded by FA may reasonably be considered to be related to the loan made by the Intermediate to Canco must be evaluated. ... Can the CRA provide a brief overview of the types of issues considered by the Directorate in recent ruling requests related to paragraph 4? ...

Would a mandatory quarantine period (imposed by the Canadian government or a foreign government) be considered a Travel Restriction? ... When is an individual’s presence in Canada considered to be “solely as a result” of Travel Restrictions? ... Q.5 — Directors Forced to Stay in Canada In the guide, CRA has considered the issue of corporate residency as it relates to directors who may be forced to travel to or remain in Canada. ...

X would only be considered to own the Shares so received from the date of the distribution. ... X's will, that acquisition is considered to be an acquisition made as a consequence of Mr. ... That acquisition will also be considered an acquisition of property made as a consequence of Mr. ...

Income from the rental of real estate is generally considered to be income from property. ... The amount received by the Spouse may therefore be considered a refund of premiums without any further formality. ... (b) Is the safe income from the sale of the assets lost or will it be considered in a future computation of safe income? ...