The Queen v. Canada Southern Railway Co., 86 DTC 6097, [1986] 1 CTC 284 (FCA) -- summary under Regulation 805

Summary Under
Tax Topics - Income Tax Regulations - Regulation 805
dividends, being themselves income from property, were not exempted notwithstanding their commercial connection to the recipinent's business

Dividends that the taxpayer paid to a US shareholder (“Penn Central”) were, as an historical matter, in lieu of amounts that Penn Central...

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Words and Phrases
income from property
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) 13