Words and Phrases - "in the course of"

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25 April 2002 Internal T.I. 2002-0131937 F - FRAIS D'EMPRUNT-EVALUATION ARPENTAGE

cost of appraisal fee required by mortgage lender was deductible

A taxpayer who used a second-mortgage loan on the individual’s residence to make interest and dividend-generating investments, was required by...

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Words and Phrases
in the course of

Glencore Canada Corporation v. Canada, 2024 FCA 3

break fee was includible under s. 12(1)(x)

An integrated nickel-mining public company (“Falconbridge”), entered into merger agreements with a more junior public company (“Diamond...

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Words and Phrases
inducement in the course of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments break fee was a capital receipt 188
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property break fee was not consideration for the disposition of a merger right as there was no such “right” 215
Tax Topics - Income Tax Act - Section 54 - Capital Property break fee was not proceeds of disposition of a capital property 176

7 April 2022 CBA Roundtable, Q.14

zero-rating under s. 2(a) for supplies to an airline relates to connected property or services, but not to the aircraft itself

Does Sched. VI, Pt. V, s. 2 zero-rate all property that is purchased or leased by a non-resident airline whose sole activity is to carry on the...

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Words and Phrases
in the course of

28 April 2004 Internal T.I. 2004-0066991I7 F - Paiement incitatif

incentive payments received from broker to purchase an exempt life insurance policy were received “in the course of earning income from … property” (the policy)

As an incentive for the sale of exempt life insurance policies (having a savings and investment component) a life insurance brokers would pay to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property property “includes practically any type of economic interest” 142
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose per MacIntyre, life insurance premiums are not deductible from business income 192

MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus...

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Words and Phrases
commission in the course of

Higgs v. Olivier (1952), 33 TC 136 (C.A.)

Before going on to find that a lump sum received by an actor in consideration for his covenant not to exercise his vocation for a period of 18...

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Words and Phrases
in the course of

Blok-Andersen v. MNR, 72 DTC 6309, [1972] CTC 338 (FCTD)

In the course of considering a submission that s. 85B(1)(B) of the pre-1972 Act (now s. 12(1)(b)) did not apply to an adventure in the nature of...

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Words and Phrases
in the course of