Words and Phrases - "reasonable"

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Pinnacle International Realty Group II Inc. v. The King, 2023 TCC 161

partnership profit reallocated under s. 103(1) based on relative contribution

The taxpayer and another wholly-owned subsidiary (“Taylor”) of the same corporation (“PIRG”) were the 5% and 95% partners, respectively,...

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Words and Phrases
reasonable

Connolly v. Canada (National Revenue), 2019 FCA 161

CRA internal guidelines on waiving the RRSP over-contribution tax were inherently unreasonable

The taxpayer did not file income tax returns for the 1988 to 2003 taxation years on the basis that as he owed no tax, this was unnecessary. Thus,...

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Words and Phrases
reasonable

Sun Life Assurance Company of Canada v. The Queen, 2015 TCC 37

holding of vacant office space by a GST-exempt business for potential future taxable rentals qualified for ITC purposes as commercial activity/first order intended supply of vancant space was for rentals

The appellant ("Sun Life"), whose principal business was the sale of financial products, subleased space in its various office buildings to...

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Words and Phrases
reasonable
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) vacant office space was used for future taxable supplies 89