Cases
Canada v. Innovative Installation Inc., 2010 DTC 5175 [at 7317], 2010 FCA 285
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| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account | receipt of insurance proceeds through debt repayment | 148 |
Wannan v. Canada, 2003 DTC 5715, 2003 FCA 423
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| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | 125 |
Banner Pharmacaps NRO Ltd. v. Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(j) | dividends recognized on cash basis | 111 |
| Tax Topics - Income Tax Act - Section 133 - Subsection 133(8) - Non-Resident-Owned Investment Corporation | dividend received when note issued/such note not a money-lenidng business | 219 |
Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | 148 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(b) | 113 |
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336
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Piché v. MNR, 92 DTC 5295 (FCA)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).
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|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | 84 | |
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | 89 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) | 90 |
Minsham Properties Ltd. v. Price, [1990] BTC 528 (Ch. D.)
Cumberland Properties Ltd. v. The Queen, 89 DTC 5333 (FCA)
C. & E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.)
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| Tax Topics - Excise Tax Act - Section 341 - Subsection 341(1) | 120 |
Parkside Leasing Ltd. v. Smith, [1985] BTC 25 (HC)
Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 74 |
Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)
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| Tax Topics - Income Tax Act - Section 76 | 42 | |
| Tax Topics - Income Tax Act - Section 9 - Interest Income | 87 |
The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)
Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 101 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 101 | |
| Tax Topics - Income Tax Act - Section 9 - Related Companies | 101 |
The Queen v. Canadian-American Loan and Investment Corp. Ltd., 74 DTC 6104, [1974] CTC 101 (FCTD)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 81 |
Blauer v. MNR, 71 DTC 5113, [1971] CTC 154 (F.C.T.A.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Partnership Interests | 81 |
Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | sale of matured interest coupons gave rise to interest receipt or amount in lieu | 194 |
Robwaral Ltd. v. MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC)
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| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | 65 |
See Also
Black v. The Queen, 2019 TCC 135
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i) | 627 |
| Tax Topics - General Concepts - Effective Date | loan was effective even though never documented and ultimately repudiated | 362 |
Borealis Geopower Inc. v. The Queen, 2018 TCC 189 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(d) | taxpayer had “physically” received unearned government assistance because it had authority to deal with the funds | 234 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(11) | loss carryback did not reduce late-filing penalty or interest | 261 |
Blott v. The Queen, 2018 TCC 1 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(ii) | retaining an assistant was not a requirement of employer | 109 |
Markou v. The Queen, 2016 TCC 137
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | TCC had jurisdiction to determine that no lender equitable remedy (under Quistclose trust doctrine) attached to leveraged donation advances | 393 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 | TCC has jurisdiction to determine existence of equitable remedy | 90 |
M. Soutar Decor 2000 Ltd. v. The Queen, 2016 TCC 62 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | transfer from guarantor by virtue of seizure of security by tax debtor’s bank | 282 |
Blank v. Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | phantom profit participation unit amounts not income until paid by employer rather than when due | 700 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | no apportionment possible between resident and non-resident services | 270 |
Great-West Life Assurance Company v. The Queen, 2015 TCC 225
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| Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) | electronic drug plan adjudication and processing was "quintessentially administrative in nature" | 265 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f.1) | essential character of drug claim processing service was providing payment to the claimant | 276 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) | services described in (r.4) did not represent the essential character of drug claim processing service | 241 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) | essential character of drug claim processing service was providing payment to the claimant | 162 |
Dimane Enterprises Ltd. v. The Queen, 2015 DTC 1013 [at 64], 2014 TCC 334
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| Tax Topics - General Concepts - Sham | purported recipients of trust distributions had no control over funds | 236 |
| Tax Topics - Income Tax Act - Section 144 - Subsection 144(1) - Employee Profit Sharing Plan | purported recipients of trust distributions had no control over funds | 236 |
Transalta Corporation v. The Queen, 2012 DTC 1106 [at 3044], 2012 TCC 86
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 59 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | no bilateral agreement to pay bonuses only in shares | 223 |
McKenzie v. The Queen, 2011 DTC 1216 [at 1274], 2011 TCC 289
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| Tax Topics - Income Tax Act - 101-110 - Section 106 - Subsection 106(3) | 390 |
Newmont Canada Corporation v. The Queen, 2011 DTC 1117 [at 628], 2011 TCC 148, aff'd 2012 DTC 5138 [at 7292], 2012 FCA 214 supra
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | loan was merely incidental to mining business | 172 |
| Tax Topics - Income Tax Act - Section 80.2 | 237 |
Sochatsky v. The Queen, 2011 DTC 1065 [at 346], 2011 TCC 41, 2012 TCC 65
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 182 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 162 |
Johnson v. The Queen, 2010 DTC 1213 [at 3568], 2010 TCC 321 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(g) | 26 |
Innovative Installation Inc. v. The Queen, 2009 DTC 1388 [at 2135], 2009 TCC 580, aff'd supra
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O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295
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| Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) | 134 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | reliance on professional opinions for technical matter | 123 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 47 | |
| Tax Topics - Income Tax Act - Section 96 | 54 |
Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.12) | 186 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | limited scope of PUC provisions reflected a policy choice | 283 |
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | 68 |
WPH Mechanical Services Ltd. v. The Queen, 2007 DTC 263, 2006 TCC 677
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| Tax Topics - Income Tax Act - Section 78 - Subsection 78(4) | 62 |
Aprile v. The Queen, 2005 DTC 585, 2005 TCC 216 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(ii) | 72 |
Hill v. The Queen, 2002 DTC 1749 (TCC)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 207 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | no Crown explanation of different treatment of simple interest | 233 |
MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) | capitalization of interest through payment and readvance respected | 124 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Term Preferred Share | 100 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 62 |
Fleishman v. The Queen, 98 DTC 1836 (TCC) (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | payment applied by creditor to principal | 68 |
Gibson v. The Queen, 95 DTC 749 (TCC)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Amount | 79 | |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 79 |
Phillips v. The Queen, 95 DTC 194 (TCC)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 97 |
Blais v. MNR, 92 DTC 1497 (TCC)
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(b) | 94 | |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 94 |
Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163 (TCC)
Re Charge Card Services Ltd., [1988] 3 All E.R. 702 (C.A.)
Associated Insulation Products, Ltd. v. Golder (1944), 26 TC 231, [1944] 2 All E.R. 203 (C.A.)
Cross v. London Provincial Trust Ltd., [1938] 1 All E.R. 428 (C.A.)
Gresham Life Society Co., Ltd. v. Bishop (1902), 4 TC 464 (HL)
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| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | no constructive receipt | 204 |
Administrative Policy
14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6 - 2019 CLHIA Q3 - 3rd party RRSP contributions
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| Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) | a 3rd party can make an RRSP contribution | 154 |
2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | subsequent year’s payment of benefit to a previously-unidentified beneficiary is only income in that year as an “in lieu of” pension amount | 606 |
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F - Attribution rules and promissory note
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| Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(2) - Paragraph 74.5(2)(b) | accrued interest cannot be “paid” for s. 74.7 purposes by issuing a promissory note | 224 |
S3-F6-C1 - Interest Deductibility
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17 June 2014 External T.I. 2013-0506731E5 - Immigration
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| Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) | dividend receivable acquired on immigration | 137 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | dividend not recognized until paid | 166 |
24 November 2013 CTF Roundtable, 2013-0508151C6 - Upstream Loans
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| Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a) | repayment by set-off | 73 |
30 January 2014 External T.I. 2013-0515761E5 F - Dividend received
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| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | book entries are ancillary and do not establish receipt | 161 |
11 December 2013 External T.I. 2013-0474161E5 - T-slips and dividend and interest
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| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | constructive receipt | 88 |
7 October 2013 Internal T.I. 2013-0504081I7 F - Interaction between 55(2) and 40(1)(a)(iii)
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) | reserve available for s. 55(2) gain on purchase for cancellation of shares where redemption proceeds payable on an earnout basis | 254 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) | s. 40(1)(a)(iii) reserve available where redemption proceeds payable on earnout basis | 165 |
6 November 2012 External T.I. 2012-0452531E5 - Satisfactory Evidence of Payment
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| Tax Topics - Income Tax Act - Section 78 - Subsection 78(4) | 157 |
13 June 2012 Internal T.I. 2012-0435351I7 F - SEPE - chèques en circulation
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | outstanding and uncashed cheques did not reduce cash | 128 |
4 July 2011 External T.I. 2011-0401991E5 F - CDA and life insurance proceeds
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| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) - Subparagraph (d)(ii) | CRA will follow Innovative Installation | 158 |
13 June 2012 External T.I. 2012-0435351E5 F -
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | cheques not yet cashed | 46 |
17 February 2004 External T.I. 2003-0033915 - Cash pooling - shareholder benefit
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) | cash pooling with NR parent | 75 |
IT-243R4, para 5
5 July 1990 TI AC59710
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 74 |
5 January 1996 Memorandum 952397 (C.T.O. "Gross-Up Payments")
30 June 1995 Memorandum 950390 (C.T.O. "Tax Status of Cheque Returned by Cash Method Farmer?")
19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops")
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| Tax Topics - Income Tax Act - Section 135 - Subsection 135(4) - Allocation in Proportion to Patronage | 39 |
May 1995 Tax Executive Institute Round Table, Q. 22 (C.T.O. "Part I.3, O/S Cheques & Overdrafts")
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| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) | 101 |
6 July 1994 Memorandum 932382 (C.T.O. "Bonds Issued in lieu of Interest")
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 91 |
1993 A.P.F.F. Round Table, Q.15
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(hh) | 65 |
26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)
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| Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) | 57 |
31 August 1992 T.I. (Tax Window, No. 24, p. 8, ¶2184)
7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 189 - Subsection 189(1) | 35 | |
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(2) | 66 |
15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(1) | 36 |
3 July 1991 Memorandum (Tax Window, No. 5, p. 22, ¶1335)
85 C.R. - Q.29
84 C.R. - Q.13
IT-436R "Reserves - Where Promissory Notes are Included in Disposal Proceeds"
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) | 0 |
IT-168R2, para. 3-4
IT-305R3 "Establishment of Testamentary Spouse Trust"
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| Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) | 0 |
IT-196R2 "Payments by Employer to Employee"
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) | 0 |
Articles
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Kevin Bianchini, Reuben Abitbol, "Taxation of Stock Appreciation Rights", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24 No. 8, 2015, p.1655
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| Other locations for this summary | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) |
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements | 389 |
E.G. McKendrick, Chitty on Contracts, Vol. 1, Thirtieth Edition (2008).
C.R.B. Dunlop, Creditor-Debtor Law in Canada, Second Edition (1994).
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | 611 |
Arnold, "Timing and Income Taxation: The Principles of Income Measurement for Tax Purposes", Canadian Tax Paper, No. 71, Canadian Tax Foundation, July 1983
Wilson, "Repayment of Shareholder Loans", 1995 Canadian Tax Journal, Vol. 43, No. 3, p. 746.
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(j) | 0 |