Oversight or Investment Management

Cases

Canada v. Rio Tinto Alcan Inc., 2018 FCA 124

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company 492
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular was not a financial report 175

The Queen v. Young, 89 DTC 5234, [1989] 1 CTC 421 (FCA)

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Firestone v. The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)

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See Also

Watson as trustee for the Murrindindi Bushfire Class Action Settlement Fund v Commissioner of Taxation, [2020] FCAFC 92

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business administration of litigation trust (generating interest income) was not a business 265

Wickham Estate v. The Queen, 2015 DTC 10125 [at 102], 2014 TCC 352 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(u) pro rata denial based on portfolio portion invested in RRIF 46
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) payments to (otherwise) retired investment manager deductible 271

Revenue and Customs Commissioner v. Peter Clay Discretionary Trust, [2009] 2 WLR 1353 (CA)

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Wilson v. MNR, 80 DTC 1379 (T.R.B.)

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Administrative Policy

6 June 2019 CPTS Roundtable, 2019-0816111C6

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) taxpayers can choose between reasonable alternative formats (e.g. hard or soft) for providing their tax working papers/records 140
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 Folio S4-F15-C1 applies for purposes of the new accelerated CCA rules 229
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) extension of M&P guidance to oil and gas sector 61
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures no acceptance that expenses incurred before decision to proceed are thereby on current account 186
Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Accelerated Canadian Development Expense - Paragraph (a) - Subparagraph (a)(ii) accelerated CDE deduction can be available for drilling on land acquired from an affiliate 131

23 March 2007 External T.I. 2006-0207071E5 - Investment Counsel Fees

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5 March 2003 External T.I. 2002-0151405 - Transaction Costs - Aborted Acquisition

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10 June 1998 Internal T.I. 9808707 - TRAVEL PROMO AND SALARY EX FOR INVEST CORP

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