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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. ...

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. ...

A taxpayer requesting an interpretation should provide sufficient information to enable the CRA to understand the issues to be considered. 12. ... Circumstances in which the CRA may not issue a ruling include when: a transaction on which a ruling has been requested is the same in character as a transaction completed by the requestor in a prior period, and the application of the relevant legislation to the earlier transaction is under discussion with the requestor, in dispute, or under assessment or proposed assessment, but is not before the courts; the CRA believes that the request may be in respect of illegal activities; a request concerns a matter in respect of which a notice of objection filed by the requestor is being considered; the central issue involves a matter that is before the courts or, if a judgement has been issued, when an appeal to a higher court is being considered; a request contains alternative courses of action on the part of the person requesting the ruling; a request is for a determination of the fair market value of property; a request involves a matter dealing with proposed or draft legislation, draft regulations, budget proposals, or notices of ways and means motions; a request concerns tax, duty, or charge-related calculations (for example, the amount of net tax due for GST/HST purposes or the amount of excise duty payable); a ruling would require an opinion on generally accepted accounting principles or commercial practices; a request is for a determination of fact, and the circumstances are such that all of the pertinent facts cannot be established (this could include issues involving the carrying on of a business, the existence of a partnership, a trust or an agency relationship, or the reasonableness of a cost allocation method); or a request is for the interpretation of a law not administered by the CRA (for example, a foreign law). 31. ...

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. ...

However, with respect to stock dividends paid after November 21, 1985 other than stock dividends declared on or before that day, subsection 15(1.1) requires the fair market value of a stock dividend to be included in income, except to the extent that it is otherwise included in the recipient's income under paragraph 82(1)(a), where it may reasonably be considered that one of the purposes of the payment of the stock dividend was to alter significantly the value of the interest of any specified shareholder of the payer corporation. ... If the share portion of the dividend was not considered to be a dividend at the time it was paid (see 8 and 11 above), the cash portion will constitute "the full amount of the dividend" where that term appears in the Act. 25. ...

To be considered a major addition, the addition must change the character of the previous complex to such a fundamental extent that the original building and the addition together essentially form a newly constructed residential complex. ... For example, if the renovation of a unit is sufficiently extensive to be considered a “substantial renovation”, the GST/HST new housing rebate will be available either to the qualifying purchaser of such a home from the “builder” or to a qualified individual if the individual carried out the renovation for his or her use as a primary place of residence or engaged a contractor to do the renovation. ...

Generally, land of ½ hectare (1.24 acres), including the land upon which your housing unit stands and any portion of the adjoining land, will be considered part of your eligible dwelling. 3. ... However, you will not be considered to own the property to gain or produce income if you receive only incidental income related to the property. 13. ...

Normally, it is considered reasonable to assume that the profit element in any amount due is that proportion of such amount that the gross profit on the sale bears to the gross selling price; thus a reserve might be allowed equal to the full amount of the profit if no part of the selling price had been received. ... A claim for a reserve equal to the lesser of the gross profit on the sale and the amount due will not be allowed as it is not considered reasonable to assume that the vendor receives no profit until after the full investment in the property sold has been recovered. 13. ...