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Although this advocacy was subordinate to its poverty-reduction purpose, it nonetheless was considered by CRA to be devoting most of its activities to (non-partisan) political activities so that it was well outside the safe harbour in ITA s. 149.1(6.2) for ancillary political activities. ...

They are considered not to be caused by the defendant’s fault that gave rise to the litigation but to be inconveniences inherent in litigation.... ...

The ARQ considered there to have been abusive surplus-stripping, and applied the Quebec general anti-avoidance rule to treat most of the paid-up capital distributions as taxable dividends. ...

It is important to emphasize that it is not actual control which must be considered, but rather the potential for the municipality to exercise such control.... ...

The ARQ considered that these fees, the accounts for which were in the name of Fontaine although addressed to the Kyard office, were occasioned by his divorce. ...

The Deputy Minister of Finance, 2019 MBQB 29-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) spouse made her own decisions re restaurant At issue was whether a corporation (“533”) whose shares were considered by the applicants to be beneficially owned by Mrs. ...

In confirming the ARQ’s reassessment made on the basis that only 54% of the taxpayer’s gain was eligible for the principal residence exemption, Breault JCQ stated (at paras. 57, 68 TaxInterpretations translation): Breault JCQ stated: [I]n order for two housing dwellings or units in the same immovable to be considered a single housing unit for the purposes of TA section 274 (or ITA 54), they must be sufficiently integrated, one with the other, such that the owner can benefit from full enjoyment of the entirety. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...

[A]lthough they constitute different cadastral lots, the cost of which was calculated separately in the deeds of sale, the interdependence and interconnection of the parking spaces to the residential units are such that they could not be considered, for the purposes of establishing the amount of the Rebate to which the purchasers were entitled, as separate components. ...

[A]lthough they constitute different cadastral lots … the interdependence and interconnection of the parking spaces to the residential units are such that they could not be considered, for the purposes of establishing the amount of the Rebate to which the purchasers were entitled, as separate components. ...

Agence du revenu du Québec, 2021 QCCQ 12137-- summary under Subsection 18(3.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(3.1) all the expenses incurred in relation to a rental home under construction from the building permit to being livable were to be capitalized The taxpayer and another individual acquired a lot for $24,500 in May 2004, and incurred various expenses during the period of construction (considered by Laurin JCQ to extend from the time of obtaining a building permit on April 4, 2004, to December 31, 2005, leased the property for one year commencing in October 2007, and the sold the property on February 1, 2011 for a price of $275,000. ...