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The GAAR committee considered similar transactions. The purpose of s. 212.1(1) is to prevent the foreign parent from accessing Canadian corporate surplus. ... In addition, the US business has been equal to, or larger than, the Canadian operations in the majority of situations considered. ... This may be the case where it could be considered that the share ownership in the foreign affiliate is transitory on the basis that it is reasonable to conclude that a subsequent disposition was contemplated at the outset. ...

Therefore, Father will be considered to have made a “contribution” to the Trust and will bea “contributor” and a “resident contributor” to the Trust. ... The proceeds received in respect of the disposition of a property of a trust would be considered substituted property. ... It is important to note that when an amount of income has become payable to a beneficiary, subsection 104(24) of the Act must be considered. ...

A bill of lading would be considered a “contract for carriage” in the common law provinces. ... For this reason, not only would Quebec Co. not be considered to have retained the carrier on behalf of Ontario Co. as acknowledged in the question, but it would also not be considered to have shipped the widgets. ... The transaction is considered “revenue neutral” as no ITC was claimed. ...

Again, the circumstances have to be considered. If USco still has to approve the transaction or the contract, but that step is a formality, the conditions could be met. ... Other considerations would have to be considered if USco has Canadian employees or employees working in Canada. ... Regarding the second leg of the distribution to the fiscally disregarded US LLC 1, the REIT would be considered to meet the conditions of Art. ...

Changes planned for 2023 include restructuring the ReFILE foundation to ensure that all the taxpayer’s latest assessed data are considered automatically. ... Some change requests are considered complex and will take longer. Due to COVID-19, the timeframe for processing adjustment requests submitted by paper can be 10 to 12 weeks. ... Some change requests are considered complex and will take longer to process. ...

IV(4) Under U.S. law, when a U.S. citizen dies, their estate may be considered a U.S. estate under U.S. domestic law. ... b) Can the CRA tell us what factors are considered by the competent authority when settling the issue? ... C’s income pursuant to s.104(13) would be considered to be US-source income – and we assume this throughout the rest of the answer. ...

The Committee also considered that such a transfer is an abuse or misuse of ss. 107(2), (2.1) and (5). ... A is deemed to receive are considered to be derived directly or indirectly from such investment business. ... Similarly, a notice in an annual or quarterly report that an eligible dividend has been paid is considered valid for that quarter. ...

If X settles a trust in 2013 with property, and then in 2017 Y contributes property to the trust, is the contribution by Y considered to fall under the word “settles”, and is Y considered a “settlor”? ... Q.7 Bitcoins as money or IPP 2013-0514701I7 stated: Virtual currencies, such as Bitcoins, are not considered to be a currency issued by a government of a country…. ... Nonetheless, it could be considered that the Property was still delivered or made available by Company B outside of Canada. ...

In the Bill C-63 proposed modification, the language that was in the original question was removed – it seems obvious that the wording was considered unnecessary. ... Paragraph 187 of the Commentary to new Article 29 sets out examples of treaty-shopping strategies commonly referred to as “conduit arrangements”, as well as arrangements that should not be considered to be conduit arrangements. ... Accordingly, in those situations where Amalco makes an election after the time that Targetco shares are delisted, Amalco will not be considered to be a public corporation. ...

The tracking interest rules in subsections 95(8) to (12) enacted by Bill C-86 now must be considered if a Canadian investor owns 10% of a class or series of shares of the umbrella corporation. ... The comfort letter provides an exception from the tracking interest rules if it cannot reasonably be considered that one of the purposes for the creation or issuance of a tracking interest in an umbrella corporation or for the acquisition of the interest by a taxpayer is to avoid the corporation being a CFA for the year. ...