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Pursuant to subsection 104(24), an amount is not considered to be payable in a taxation year unless it is paid in the year to the person to whom it is payable or the person to whom it is payable is entitled in the year to enforce payment thereof. ... It should be noted that foreign accrual property income of a non-resident trust is included in the income of a beneficiary pursuant to paragraph 104(13)(c) to the extent that the amount may reasonably be considered to have become payable to a beneficiary within the meaning of subsection 104(24). ... The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. ...

In addition, payments made for the purchase of works of art from a self-employed artist under the Art Bank program of the Council are not grants but are considered to be ordinary business income to the artist; accordingly, such payments are included in the income or loss under section 9. ... When a taxpayer receives an amount by virtue of or in connection with an office or employment, it is considered employment income under subsection 5(1). ... In another case when, for instance, an artist is selected by the Council for training or development through an arrangement under which the artist is placed under an employer for a small salary or no salary while the Council subsidizes the artist's employment income, the assistance from the Council to the artist, whether paid directly or through the employer, is considered to be received by virtue of the employment, and is therefore taxable in the artist's hands as income from employment. ...

When completing the T3 return, follow the instructions in the T3 guide, and make sure that you: (a) complete all of the identification area on page 1; (b) identify the trust as a communal organization; (c) do not deduct any amount for salaries, wages, or benefits of any kind paid to any members of the congregation when calculating the trust's taxable income; (d) if you make an election regarding taxable income, determine the trust's modified taxable income; (e) if you make an election regarding donations and gifts, enter on Schedule 9, Summary of Income Allocations and Designations to Beneficiaries, the total amount of charitable donations and Crown and cultural gifts designated to members of the congregation; and (f) if the trust is allocating business, farming, or fishing income, enter on Schedule 9, in the area called "self-employment earnings," the total amount of business, farming, and fishing income allocated, since it is considered to be self-employment income for CPP contributions. 20. ... The income the trust allocates will be considered to be the income of the beneficiaries for the year from a trust. ... However, business income allocated by the trust is considered to be self-employment earnings for Canada Pension Plan contributions. 24. ...

An entity must meet all of the conditions set out in this definition to be considered a non-profit organization for the purposes of the Act. ... A non-profit organization is considered to have been "established primarily for the benefit of organized labour" if it was established primarily to provide some advantage to organized labour, such as: a trade union as defined in section 3 of the Canada Labour Code; a trade union as defined in any provincial act that provides for the investigation, conciliation, or settlement of industrial disputes; an association of public servants whose primary object is to promote the improvement of the members’ conditions of employment or work; or a parity or advisory committee or similar body. 15. ... Therefore, Organization A is considered to have been "established primarily for the benefit of organized labour". ...

Where all of the above conditions are met, subsection 183(3) applies and the supply of the property would be considered to be a supply made otherwise than in the course of a commercial activity. ... A judicial sale will also be considered to fall within subsection 183(10) on the basis that these are "rights" available to creditors under statute law. ... All the conditions of subsection 183(3) have been met and, therefore, the supply is considered to have been made otherwise than in the course of a commercial activity. ...

Thus as stated above, because there in Québec is a possibility that the previous owner will redeem the property within a prescribed time period following the auction sale and because of the effect of the redemption, the issue is whether in that province the auction sale can be considered a supply for GST purposes. ... B is considered to be selling the land back to Mr. A for $ 53,500 plus interest. ... B is considered to be selling the land back to Co. A for $ 100,000 plus interest. ...

Policies to be reported A contract is considered to be entered into or renewed on the effective date of the contract unless the contract provides that the premiums are payable on a date other than the effective date. In this case, for purposes of filing your return, the contract is considered to be entered into or renewed on the premium payable date. ... Where contracts of insurance are validly placed with unlicensed insurers under the above conditions, the insurer can be considered authorized to transact the business of insurance in the context of Part I of the Excise Tax Act. ...

. ¶1.31 has been modified for clarity by replacing the words “sets out the deemed dispositions which are not considered” with the words “provides that certain dispositions and acquisitions of property that are either deemed to be made by certain provisions of the Act or made in the course of certain rollover transactions are not dispositions or acquisitions”. ¶1.39 has been modified to improve readability by adding the words “paid by the partnership” immediately after the words “of the total foreign taxes” in the third sentence. ¶1.39.1 has been added to take into account the rules regarding artificial foreign tax credits generators under subsections 126(4.11) to (4.13) as enacted by S.C. 2013, c. 34 (formerly Bill C-48), s. 267(4). ... The reference to resource royalties was removed from the discussion of taxes in general since they may be a payment for a specific right or privilege, or may be part of a regulatory scheme and moved to the discussion of examples of what will not be considered an income or profits tax, to address the situation where they may be structured as a tax. ¶1.6 (formerly included in ¶5 of IT-270R3) now includes an additional bullet to reflect the operation of subsection 126(4). ¶1.7 (formerly included in ¶5 of IT-270R3) has been revised to reflect the primacy of Canadian law for characterizing a transaction, and calculating the income for the purposes granting a foreign tax credit in accordance with the language of section 126. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

A stop between two legs of a journey that is 24 hours or less is not considered to be a stopover. However, a stop of more than 24 hours between two legs of a journey will generally be considered a stopover where two or more tickets or vouchers are issued for the legs of the journey. ... Therefore, each ticket has to be considered separately to determine whether GST or HST applies. ...

When completing the T3 return, follow the instructions in the T3 guide, and make sure that you: (a) complete all of the identification area on page 1; (b) identify the trust as a communal organization; (c) do not deduct any amount for salaries, wages, or benefits of any kind paid to any members of the congregation when calculating the trust's taxable income; (d) if you make an election regarding taxable income, determine the trust's modified taxable income; (e) if you make an election regarding donations and gifts, enter on Schedule 9, Summary of Income Allocations and Designations to Beneficiaries, the total amount of charitable donations and Crown and cultural gifts designated to members of the congregation; and (f) if the trust is allocating business, farming, or fishing income, enter on Schedule 9, in the area called "self-employment earnings," the total amount of business, farming, and fishing income allocated, since it is considered to be self-employment income for CPP contributions. 20. ... The income the trust allocates will be considered to be the income of the beneficiaries for the year from a trust. ... However, business income allocated by the trust is considered to be self-employment earnings for Canada Pension Plan contributions. 24. ...