(m)-(p)

Paragraph 20(1)(m) - Reserve in respect of certain goods and services

Cases

Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153 (FCTD)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) 77
Tax Topics - Income Tax Act - Section 9 - Timing future obligation for offsetting tariff reduction 106

Dixie Lee (Maritimes) Ltd. v. The Queen, 88 DTC 6108 (FCTD), aff'd 91 DTC 5518 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Timing substantial performance of services for franchise fees 148

Burrard Yarrows Corp. v. The Queen, 86 DTC 6459, [1986] 2 CTC 313 (FCTD), aff'd sub nomine Versatile Pacific Shipyards Inc. v. The Queen, 88 DTC 6352 (FCA)

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Sears Canada Inc. v. The Queen, 86 DTC 6304, [1986] 2 CTC 80 (FCTD), aff'd 89 DTC 5039 (FCA)

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Dominion Stores Ltd. v. MNR, 66 DTC 5111, [1966] CTC 97 (Ex Ct)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 68 70

See Also

Doteasy Technology Inc v. The Queen, 2009 DTC 1019, 2009 TCC 324

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Ellis Vision Incorporated v. The Queen, 2004 DTC 2024, 2003 TCC 912

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Provincial Law 38

Blue Mountain Resorts Ltd. v. The Queen, 2002 DTC 1886 (TCC)

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Deputy Minister of Revenue for Quebec v. Le Compagnie Meloche Inc., 2002 DTC 7169 (Que. CA)

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Redhead Equipment Ltd. v. The Queen, 2001 DTC 429 (TCC)

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Gagnon v. The Queen, 99 DTC 845 (TCC)

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I.B. Pedersen Ltd. v. The Queen, 94 DTC 1085 (TCC)

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Administrative Policy

2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions 272
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up 279
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) continuation of s. 34.2(11) reserve following partnership wind-up 324
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up 262
Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) s. 20(24) election on s. 98(5) wind-up 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up 216
Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) s. 147.2 continuity following s. 98(5) wind-up 336
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs 329
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) no income on RSU/DSU assumption 20

16 February 2016 External T.I. 2015-0618601E5 - Earned or Unearned Revenue

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Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(2) no deferral of lump sum received on signing 15-year supplier loyalty agreement 176
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) lump sum received on signing 15-year supplier loyalty agreement was immediately recognized inducement 194

9 October 2015 APFF Roundtable Q. 9, 2015-0595661C6 F - Question 9 - Table Ronde APFF 2015

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Tax Topics - Income Tax Act - Section 9 - Timing damages clause might represent a condition permitting deferral of income recognition 238

20 August 2015 External T.I. 2015-0588871E5 - Taxation of insurance contract commission income

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Tax Topics - Income Tax Act - Section 32 - Subsection 32(1) - Paragraph 32(1)(b) reserve not available based on potential claims processing 232

10 October 2014 APFF Roundtable, 2014-0538131C6 F - revenus d'achats intégrés

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) full inclusion for in-app sales 62

7 October 2005 APFF Roundtable Q. 26, 2005-0141171C6 F - Prepaid Income - Reserves when no contingency

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27 September 2004 External T.I. 2003-004824 -

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20 November 2003 External T.I. 2003-003354 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) partnership is taxpayer/application to s. 98(5) wind-up 66

1994 APFF Round Table, Q. 4

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92 C.R. - Q.39

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10 October 1991 T.I. (Tax Window, No. 11, p. 22, ¶1516)

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4 September 1991 Memorandum (Tax Window, No. 9, p. 20, ¶1440)

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24 July 1991 T.I. (Tax Window, No. 7, p. 17, ¶1370)

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29 January 1990 T.I. (June 1990 Access Letter, ¶1250)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) 54

1 December 1989 T.I. (May 1990 Access Letter, ¶1209)

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89 C.P.T.J. - Q11

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 31

89 C.M.TC - Q.2

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Paragraph 20(1)(n) - Reserve for unpaid amounts

Cases

Wollfsky v. The Queen, 2001 DTC 5316 (FCA)

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Wolofsky v. The Queen, 2000 DTC 6302 (FCTD)

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Regina Shoppers Mall Ltd. v. The Queen, 90 DTC 6427 (FCTD)

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Tax Topics - Statutory Interpretation - Resolving Ambiguity 89

Ennisclare Corp. v. The Queen, 83 DTC 5018, [1982] CTC 428 (FCTD), aff'd 84 DTC 6262, [1984] CTC 286 (FCA)

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Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)

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Abed Estate v. The Queen, 82 DTC 6099, [1982] CTC 115 (FCA)

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Choice Realty Corp. v. The Queen, 78 DTC 6415, [1978] CTC 613 (FCTD)

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The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)

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Home Provisioners (Manitoba) Ltd. v. MNR, 58 DTC 1183 (Ex Ct)

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Words and Phrases
sale

See Also

Odyssey Industries Inc. v. The Queen, 96 DTC 498 (TCC)

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Leonard Reeves Inc. v. MNR, 91 DTC 425 (TCC)

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Lloyds & Scottish Finance Ltd. v. Cyril Lord Carpets Sales Ltd., [1992] B.C.L.C. 609 (HL)

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Administrative Policy

2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions 272
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up 279
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) continuation of s. 34.2(11) reserve following partnership wind-up 324
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up 266
Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) s. 20(24) election on s. 98(5) wind-up 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up 216
Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) s. 147.2 continuity following s. 98(5) wind-up 336
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs 329
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) no income on RSU/DSU assumption 20

S4-F7-C1 - Amalgamations of Canadian Corporations

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Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 103
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 155
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 126
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 145
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 97
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 82
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 164
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) realted party, majority and 50% group exceptions 448
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 103
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 104
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 159
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 81
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 60
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 114
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 47
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 260
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 0
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 135
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 133
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 159
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 38
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 328
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 181
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 247
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 171
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 218
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 106
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 56
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 123
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 415
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 323
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 311
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 96

93 C.P.T.J. - Q.18

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25 July 1991 T.I. (Tax Window, No. 7, p. 10, ¶1372)

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21 September 1990 Memorandum (Tax Window, Prelim. No. 1, p. 7, ¶1003)

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6 March 1990 T.I. (August 1990 Access Letter, ¶1368)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 76 40

84 C.R. - Q.17

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) 25

Paragraph 20(1)(p) - Bad debts

Subparagraph 20(1)(p)(i)

Cases

Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at 7292], 2012 FCA 214

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Estate of the late Donald Mills v. The Queen, 2010 DTC 1301 [at 4078], 2010 TCC 443, aff'd 2011 DTC 5124, 2011 FCA 219

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) no bad debt deduction 73

Global Communications Ltd. v. The Queen, 98 DTC 6649 (FCTD)

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Harrowston Corp. v. The Queen, 96 DTC 6544 (FCA)

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Flexi-Coil Ltd. v. The Queen, 96 DTC 6350 (FCA)

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Sutherland v. The Queen, 91 DTC 5318 (FCTD)

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Saskatchewan Co-Operative Credit Society Ltd. v. The Queen, 84 DTC 6225, [1984] CTC 628 (FCTD), aff'd 85 DTC 5599 [1986] 1 CTC 53 (FCA)

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Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA)

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Associated Investors of Canada Ltd. v. MNR, 67 DTC 5096 (Ex. Ct.)

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Frontenac Shoe Ltée v. MNR, 63 DTC 1129 (Ex Ct)

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See Also

Hokhold v. The Queen, 2017 TCC 217

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Delle Donne v. The Queen, 2015 TCC 150

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract "debt" exists irrespective of demand 87
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) reserve could be claimed on appeal 82
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) doubtful debt reserve claimed implicitly as at the year end in light of subsequently revealed information 477

Francis & Associates v. The Queen, 2014 DTC 1146 [at 3468], 2014 TCC 137 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) taxpayers held to standard of wise and prudent law partner 118

Supercom Canada Limited v. The Queen, 2005 DTC 1438, 2005 TCC 589

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Williams Gold Refining Co. of Canada v. The Queen, 2000 DTC 1829 (TCC)

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Anjalie Enterprises Ltd. v. The Queen, 95 DTC 216 (TCC)

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E.C.E. Group Ltd. v. MNR, 92 DTC 2019 (TCC)

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Roy v. MNR, 58 DTC 676 (TAB)

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Hogan v. MNR, 56 DTC 183, 15 Tax ABC 1

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Administrative Policy

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

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11 October 2013 APFF Roundtable, 2013-0495671C6 F - Déduction d'une partie d'une créance irrécouvrable

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) comparison of 20(1)(p)(i) and 50(1): latter requires full uncollectibility 160

14 December 1993 Memorandum 931814 (C.T.O. "Bad Debt Reduction for Part of a Loan")

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17 August 1992, T.I. 921353 (April 1993 Access Letter, p. 135, ¶C20-1141)

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ATR-6 (22 Jan. 86)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 76 66

IT-442R "Bad Debts and Reserves for Doubtful Debts"

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Articles

Tetreault, "Canadian Tax Aspects of Asset Securitization", 1992 Conference Report, p. 23:16.

Novek, "Deductibility of Financing Expenses", 1992 Corporate Management Tax Conference, c.3.

Frankovic, "Taxing Times: Foreclosures, Default Sales, Debt Forgiveness, Doubtful and Bad Debts", 1991 Canadian Tax Journal, p. 889.

Subparagraph 20(1)(p)(ii)

Cases

725685 Alberta ltd. v. Canada, 2009 DTC 6027, 2009 FCA 194

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Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra

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Words and Phrases
loan money-lending business

Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)

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The Queen v. Doral Investment Corp., 79 DTC 5316, [1979] CTC 398 (FCTD)

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Chaffey v. M.N.R., 78 DTC 6176, [1978] CTC 253 (FCA)

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The Queen v. Pollock Sokoloff Holdings Corp., 76 DTC 6181, [1976] CTC 349 (FCA)

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The Queen v. E. V. Keith Enterprises Ltd., 76 DTC 6018, [1976] CTC 21 (FCTD)

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The Queen v. Lavigueur, 73 DTC 5538, [1973] CTC 773 (FCTD)

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Rossmor Auto Supply Ltd. v. MNR, 62 DTC 1080 (Ex. Ct.)

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See Also

Groscki v. The Queen, 2017 TCC 249 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 159 - Subsection 159(3) a director was not liable for failure to obtain a s. 159(2) certificate before his corporation disposed of most of its assets 298
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Legal Representative director without liquidator authorization was not legal representative 84

Meilleur v. The Queen, 2016 TCC 287

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Words and Phrases
loan

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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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt no implied set-off 165
Tax Topics - Income Tax Act - Section 80.2 237

Zaenker v. The Queen, 2007 DTC 1365, 2007 TCC 440

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Martin v. The Queen, 2007 DTC 1284, 2007 TCC 339 (Informal Procedure)

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Langhammer v. The Queen, 2001 DTC 45 (TCC)

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576315 Alberta Ltd. v. The Queen, 2001 DTC 776 (TCC)

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Yunger v. The Queen, 2000 DTC 2153 (TCC)

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Loman Warehousing Ltd. v. The Queen, 99 DTC 1113 (TCC), aff'd 2000 DTC 6610 (FCA) supra

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Singh v. The Queen, 2000 DTC 2031

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Whitland Construction Co. v. The Queen, 99 DTC 33 (TCC)

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Wesco Property Developments Ltd. v. MNR, 89 DTC 590 (TCC)

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Robitaille v. American Biltrite (Canada), [1985] 1 S.C.R. 290

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Highfield Corp. v. MNR, 82 DTC 1835 (TRB)

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Administrative Policy

6 March 1995 Memorandum (C.T.O. "Money Lending Business")

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7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)

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7 August 1992, T.I. 920376 (May 1993 Access Letter, p. 192, ¶C20-1145)

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Articles

Guy Fortin, Melanie Beaulieu, "The Meaning of the Expressions ‘In the Ordinary Course of Business' and ‘Directly or Indirectly'", 2002 Conference Report (Toronto: Canadian Tax Foundation, 2003) 36:1-60.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.3) 0