Cases
Evans v. The Queen, 87 DTC 5226, [1987] 1 CTC 316 (FCTD)
The taxpayer acquired a motorhome in 1980 with the intention of renting it out in 1981 as a business endeavour. The leasing property restriction...
See Also
Agence du revenu du Québec v. J.D. Irving Limited, 2022 QCCA 241
The taxpayer (“JDI”) and another pulp and paper company in the Irving group (“IPPL”) engaged in several transactions to effectively...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | agency relationship respected so as to permit owner to charge for services performed by user | 281 |
J.D. Irving Limited v. Agence du revenu du Québec, 2020 QCCQ 2423, aff'd 2022 QCCA 241
The taxpayer ("JDI") and another pulp and paper company in the Irving group (“IPPL”) participated in transactions to effectively transfer...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | Stubart recognized that business operations can be carried on by an affiliated agent | 231 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | loss consolidation transaction entailing circular transfers of depreciable property confirmed | 90 |
Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)
A British corporation ("WBDL") entered into a distribution agreement with a California corporation ("WBI") pursuant to which WBI was granted the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 136 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | 240 | |
| Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1) | main purpose was to make a profit, not take deduction | 264 |
General Motors Acceptance Corp. (U.K.) Ltd. v. I.R.C., [1985] BTC 324 (HC), aff'd [1987] BTC 71 (C.A.)
In the ordinary course of trade of a finance subsidiary ("GMAC"), it provided a financial package to car dealers, which entailed (1) GMAC...
Canadian Acceptance Corp. Ltd. v. Regent Park Butcher Shop Ltd. (1969), 67 WWR 297 (Man. C.A.)
Dickson J.A. found that the hiring of a cash register was a chattel lease notwithstanding a clause that provided that the lease was irrevocable...
Crawford v. Kingston, [1952] OR 715 (C.A.)
In finding that an agreement pursuant to which the plaintiff transferred 14 cows to his brother-in-law who was required to return the same number...
Administrative Policy
8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping
In finding that a campground generally would not be subject to the rental property restriction rules, the Directorate stated:
[P]aragraph 7 of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 - Paragraph 17(c) | costs of developing a campground would generally be added to Class 17(c) | 98 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 | septic tanks are structures | 167 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 | swimming pool is a water storage tank | 98 |
14 September 1992, T.I. (Tax Window, No. 24, p. 15, ¶2217)
Leasing property can include application software. In any event, Regulation 110(17.2) extends the concepts of rent to include gross revenue...