Subsection 207.06(1) - Waiver of tax payable
Cases
Ifi v. Canada (Attorney General), 2020 FC 1150
Sangha v. Canada (Attorney General), 2020 FC 712
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | delegate's decision failed to contain “a coherent assessment of the relevant law and significant facts and submissions” | 303 |
See Also
Robitaille v. The Queen, 2019 TCC 200 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.02 | a fully-unintended TFSA overcontribution generated over-contribution tax | 219 |
Administrative Policy
Subsection 207.06(2)
Cases
Hunt v. Canada, 2020 FCA 118
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 53 | inadequate submissions for considering whether CRA discretion to waive tax was unconstitutional | 461 |
Louie v. Canada, 2019 FCA 255
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) - Subparagraph (b)(i) | advantages generated in Year 1 from swap transactions continued to produce indirect advantages thereafter | 547 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | no necessity for predetermined endpoint or advance determination of price | 211 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | taxpayer was directing mind in transactions involving an arm’s length trustee | 137 |
See Also
Hunt v. The Queen, 2018 TCC 193, aff'd on narrower grounds 2020 FCA 118
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.05 - Subsection 207.05(2) | discretion under s. 207.06(2) did not render s. 207.05 unconstitutional | 371 |
| Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 91 - Subsection 91(3) | 100% TFSA advantage tax did not infringe provincial property-and-civil-rights power | 233 |
| Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 53 | CRA’s discretion to waive tax does not render the tax unconstitutional | 155 |
Administrative Policy
S3-F10-C2 - Prohibited Investments – RRSPs, RRIFs and TFSAs
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