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Examples of ethnocultural group activities that could qualify as the advancement of religion teaching a religion running a religious school establishing a mosque, church, temple, or other place of worship for religious uses repairing a place of worship (iv) Other purposes that benefit the community Generally, purposes that fit under the relief-of-poverty, the advancement-of-education, and the advancement-of-religion categories are considered to benefit the community even if they are focused on an ethnocultural group. ... For example, banquets, picnics, and Canada Day celebrations are not considered charitable purposes. ... A Canadian charity can only transfer sums of money or other resources to foreign charities that are considered qualified donees. ...

A Crown charge does not include a tax or any portion of tax that may reasonably be considered to be a municipal or school tax or any amount prescribed in section 1211 of the Regulations. ... (e) If an operator of a Canadian resource property disposes of production from that operation to the Crown, and simultaneously or subsequently acquires production from that operation from the Crown for an amount that exceeds its fair market value, subsection 69(7) applies to deem the acquisition to be at fair market value as determined under subsection 69(9) (see 11 and 16 below), and if the disposition to the Crown was made at less than fair market value, subsections 69(6), 69(8) and 69(10) are not considered to apply to that disposition. ... When the specific conditions in subsection 69(9) exist, that is, when there is a disposition to and a buy back from the Crown of a particular quantity of production by the producer, subsections 69(6), 69(8) and 69(10) are considered not to apply to the disposition to the Crown if that disposition was made at less than fair market value. ...

Changes in use of capital property that are insignificant are not considered to be changes in use for the purposes of the Act. ... Where such changes of less than 10 per cent accumulate to 10 per cent or more, the accumulated changes are considered to be a significant change, invoking the change in use rules. ... The registrant is considered to have sold the computer at its fair market value at that time. ...

Consideration is considered to be "paid" when the supplier receives the money, property or service which is consideration for the supply. ... Under this broad definition, any record of a supply which sets out the goods or services which make up the supply, along with the consideration due or paid for the supply, will be considered to be an invoice. ... Where a person gives a deposit in respect of a supply, (other than an amount in respect of a covering or container in respect of which section 137 applies to deem the covering or container to be part of the property supplied), that deposit is not considered to be consideration for the supply unless and until the supplier applies the deposit against the consideration for the supply or the deposit is forfeited. 43. ...

Where a full ITC is not available to the recipient, the transaction will not be considered a wash transaction. ... The waiver of penalty and interest in excess of 4% of the tax not properly charged or the ITCs not properly accounted for in a wash transaction will normally be considered automatically by the CRA during the audit process. ... The waiver of interest in excess of 4% of the tax not properly charged in a wash transaction will normally be considered automatically by the CRA during the audit process. ...

In making a determination of whether or not a PE exists, there are numerous factors to be considered that are outlined in the OECD Model Commentary and derived from jurisprudence. ... Taking a different view could result in only the headquarters of a business ever being considered a PE and this would generally defeat the purpose of Article 5 (Permanent Establishment) and Article 7 (Business Profits) of our treaties since the headquarters of a business are generally located in the state of residence of the person carrying on the business. ... The discussion above is only intended to provide some examples of factors that could be considered. ...

More specifically, it applies where a person or partnership acquires or disposes of shares of the capital stock of a corporation or interests in a partnership, either directly or indirectly, and it can reasonably be considered that the principal purpose for the acquisition or disposition is to permit a person to avoid, reduce or defer the payment of tax or any other amount that would otherwise be payable under the Act (referred to in this article as a “tax benefit”). ... The words of paragraph 95(6)(b) are broad and could be considered to apply to a wide range of transactions. ... For example, even though a purpose of the person making a share acquisition may be to earn a return on that investment, if a tax benefit is enjoyed by another person by virtue of the share acquisition, the acquisition may nevertheless be considered to have been made principally for the purpose of creating the tax benefit. ...

Consequently, a deduction is not allowed for what might otherwise be considered to be the capital element of an amount so received. ... Payments under the contract will be considered annuity payments with a capital element equal to the applicable portion of the original cost of the annuity that was included in income. ...

Persons who have control of the corporation are considered not to deal at arm's length with the corporation. Corporations that are connected by the same controller ownership are also considered to be related. ...