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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. ...

However, a conversion or rollover from qualified employer sponsored retirement plan accounts (such as traditional 401(k)s and profit sharing plans) or traditional IRAs to a Roth IRA after December 31, 2008 will be considered a Canadian Contribution. ... If a Canadian Contribution is made to the Roth IRA, a portion of the Roth IRA will cease to be considered a "pension" for purposes of Article XVIII. ...

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. ...

The creditor is neither the beneficiary of the policy nor the policyholder and would not be entitled to include the proceeds in its capital dividend account because the amount it receives would not be considered to be proceeds of a life insurance policy. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...

To be considered incidental, a supply generally plays only a minor or subordinate role in relation to the provision of another supply. ... The provision of the educational service can be considered to be a supply distinct and independent from the supply of the books. ...

A vendor is considered to be in a remote location when: the vendor is serviced by year-round road access, and is located over 350 kilometres from the nearest community with a population of 5,000 or more, by the most direct route normally travelled in the circumstances, or surface transportation is not available year-round on paved or gravelled roads linking the vendor with the nearest established community. ... Please note, a vendor in an established community that is not linked by year-round roads to other communities is not considered to be in a remote location. ...

Category 3 – A body that meets all the following criteria: The ordinary meaning of the term “established” when considered in the context of the words “other body established by a government” in the Act includes more than a body that is created by a government. ... Where the government has been involved in the setting up of the body for a specific purpose such that its actions indicate a clear intention to set up a “new body” that did not exist in that capacity before, that body might be considered “established” by a government. ...

January 2005 Note This policy statement does not apply to leases, licences or similar arrangements for a specified motor vehicle made on or considered to have been made on the lands of a First Nation where a FNGST has been imposed. ... Given the facts in this example, the FNGST will have to be applied to the lease payments as the supply is considered to be made on FNGST lands because that is where the person ordinarily resides. ...

The Canadian purchaser is the importer and therefore responsible for paying the GST under Division III of the Excise Tax Ac t if the software is considered to be "imported goods" within the meaning of section 212. ... Division III- GST charged by Customs Value for duty of disk $18.00(Canadian) GST ($18.00x7%) $1.26 (b) Since the licensed custom software is considered to be intangible personal property and this supply is not acquired for use exclusively in the course of commercial activities of the recipient, the Canadian licensee (the financial institution) is required to self-assess the tax under Division IV on the amounts paid to the non-resident supplier in respect of the software. ...

CRA administrative position The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ... However, the component of the premium referred to above as the margin for risk transfer is not considered to be included in loading and is not subject to tax under the import rules. ...