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Technical Interpretation - External
5 March 2024 External T.I. 2023-0962831E5 - Active business income – Income from solar panels
Generally, if the principal purpose of the business is to derive income from property, the business could be considered a SIB. ... To be considered an active business, the activity should first qualify as a business. ... It should be noted that the "principal purpose" of a corporation must be determined annually after all the facts relating to the business (or businesses) carried on by that corporation in that year have been considered and analyzed. ...
Technical Interpretation - External
2 May 2024 External T.I. 2024-1003831E5 - Active assets - intangible assets
If the withdrawal of the property would have a decidedly destabilizing effect on the corporate operations, the property would generally be considered to be used in the course of carrying on a business. ... Generally, an asset is considered to be used principally (i.e., more than 50%) in an active business if its primary or main use is in that business. ...
Technical Interpretation - External
23 April 2024 External T.I. 2024-1004511E5 - AITC and fuel production
In particular, you asked whether the production or processing of fuel could be considered to be the manufacturing or processing of a good for sale in the context of the AITC. ... (footnote 5) The Act does not otherwise specify what is considered to be manufacturing or processing goods for sale or lease in the context of the AITC. ... Based on the foregoing, in our view the production or processing of a fuel could be considered to be the manufacturing or processing of a good for sale for purposes of the AITC, depending on the particular circumstances. ...
TCC
MIL (Investments) S A v. The Queen, 2006 DTC 3307, 2006 TCC 460, aff'd 2007 FCA 236
You would have been aware that if cash was provided that it would have been considered to be a taxable gain. ... The Board fully discussed the Revised Falconbridge Offer, and carefully considered the advice of its legal counsel and financial advisors. ... In view of the variety of factors considered in connection with its valuation of the Arrangement, the Board of Directors did not quantify or otherwise attempt to assign relative weights to the specific factors considered in reaching its determination. ...
SCC
Deloitte & Touche v. Livent Inc. (Receiver of), 2017 SCC 63, [2017] 2 SCR 855
Hobart, 2001 SCC 79, [2001] 3 S.C.R. 537, this Court provided greater certainty to the law of tort by clarifying the factors which may be considered at each stage of the Anns test. ... In cases of negligent misrepresentation or performance of a service, however, proximity will be more usefully considered before foreseeability. ... However, since Cooper it has been clear that policy considerations relating to the relationship between the parties fall to be considered at the first step of Anns. ...
TCC
Dow Chemical Canada ULC v. The Queen, 2020 TCC 139, rev'd 2022 FCA 70
[Emphasis added.] [46] Finally, I have considered statements made in the context of the introduction of Part XVI.1. ... In doing so, it considered whether the Minister “proceeded on just, reasonable and admissible grounds” in deciding not to permit any depletion allowance. ... Conduct of officials of the nature considered in these cases is too far removed from the correctness of the assessment. ...
Ruling
2010 Ruling 2009-0347271R3 - Foreign Affiliate Restructuring Financing
Where a foreign entity is considered to be a corporation for the purposes of the Act but ownership in the entity is not divided into units entitled shares, can an ownership interest in such an entity be considered to be shares in the capital stock of that entity for the purposes of the Act. 3. ... For purposes of the Act: (i) Finco will be considered a corporation; (ii) the ownership interests in Finco will be considered shares of Finco; (iii) Pubco's equity percentage in respect of Finco will be 100%; (iv) Finco will be a foreign affiliate and a controlled foreign affiliate of Pubco; (v) Pubco will have a qualifying interest in respect of Finco and will be related to Finco; and (vi) distributions of Finco's profit to its equity holder(s) will be considered dividends. ... For purposes of the Act: (i) Forco1 will be considered a corporation; (ii) the ownership interests in Forco1 will be considered shares of Forco1; (iii) Pubco's equity percentage in respect of Forco1 will be 100%; (iv) Forco1 will be a foreign affiliate and a controlled foreign affiliate of Pubco; (v) Pubco will have a qualifying interest in respect of Forco1 and will be related to Forco1; and (vi) distributions of Forco1's profit to its equity holder(s) will be considered dividends. ...
TCC
Mariano v. The Queen, 2015 DTC 1209 [at at 1331], 2015 TCC 244
Mariano testified that she was motivated by her desire to help others as well. [28] While I appreciate the subjective intention of the appellants must always be considered, such stated intention is not determinative but must be based in some objective reality. ... Dobner considered the wrong market [103] Mr. Dobner relied on a notional transaction between an educational customer (i.e., a non‑profit organization that provides or oversees the provision of education services, such as district school boards) and a supplier of Donated Licences (e.g. ... Dobner’s report- Appendix “D” above, which, as expressed in paragraph 21 thereof, includes the Precedent Transaction Method under which “… valuation ratios are derived from open-market transactions of assets which are considered to be the same or similar as the subject asset”. [143] The point being, that although Mr. ...
TCC
Fiducie Financière Satoma v. The Queen, 2017 TCC 84, aff'd 2018 FCA 74
This is explained by the fact that the income was already included in the income of the person who, under subsection 75(2) of the ITA, is deemed to have earned the income and that income is therefore considered part of the trust’s capital (CRA Views, Taxnet Pro, document 9411115- Attribution). ... It is not reasonable to think that this other arrangement proposed by the appellant could have been seriously considered, given the taxation in the hands of Louis Pilon that such a transfer of funds in the trusts of which he was a beneficiary would entail under section 15 of the ITA. [75] In my opinion, it is therefore clear that the primary goal of the proposed plan, from the moment subsection 75(2) was engaged, was to avoid the payment of any tax by the trust and any beneficiary of the trust. ... If that is not the case, the trust is taxed on that income, and any subsequent distribution to its beneficiaries will be considered a non-taxable distribution of the trust’s capital. [96] As to of the corporate tax regime, the corporation will first be taxed on its income and the shareholder who receives a dividend from that corporation will also be taxed on that dividend. [97] If the dividend is paid to an individual, the ITA provides for an integration arrangement. ...
SCC
Keatley Surveying Ltd. v. Teranet Inc., 2019 SCC 43, [2019] 3 SCR 418
Belobaba J. considered the seven Common Issues (Keatley Surveying Ltd. v. ... With the development of the printing press, printing in England was considered to be a matter of state. ... In determining whether a particular work is a government work, then, the purpose of the work must be considered. ...