Cases
Bishay v. MNR, 95 DTC 5619, [1996] 1 CTC 2286 (FCTD)
The taxpayer filed tax returns for her medical practice showing a December 31 year end and then, shortly before the Minister issued assessments on...
Matthys v. R., 86 DTC 6385, [1986] 2 CTC 307 (Ont. D. Ct.)
A partner of a farming partnership was held to be entitled to include his share of income from the rental of tobacco quotas on a fiscal-year...
See Also
Sybron Canada Ltd. v. R., 99 DTC 878, [1999] 3 CTC 2695 (TCC)
After there was an acquisition of control of a predecessor of the taxpayer ("Holdco") on October 16, 1987 (thereby giving rise to a new taxation...
Administrative Policy
5 January 1995 Income Tax Technical News, No. 6
When a partnership agreement requires that certain expenses incurred by a partner must be paid for by her, RC will require (with effect for such...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) | futures, forwards and options | 81 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 61 |
7 September 1994 Internal T.I. 9406256 - FIRST AND LAST TAXATION YEAR OF A TESTAMENTARY TRUST
Discussion of the Szczupak (59 DTC 119) decision, and reference to the dictionary meanings of "accept" and "adopt".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(23) - Paragraph 104(23)(a) | 82 |
25 March 1994 External T.I. 9329965 F - Subsection 115(4) of the Income Tax Act
The taxation year of a branch will not be considered to have ended on the date that the assets of the branch are transferred to a Canadian...
93 C.R. - Q. 20
A corporation's first fiscal period will commence on the day of incorporation rather than on the later day on which it commences operations.
89 C.R. - Q.40
RC will normally allow a joint venture to establish its own fiscal period which may differ from the fiscal period of each joint venture. "This...
89 C.P.T.J. - Q12
Where two corporations with calendar year-ends amalgamate on July 1, 1989, and retain calendar year reporting for securities and financial...
89 C.M.TC - Q.15
RC's administrative position on fiscal periods for joint ventures is intended to apply where the participants have different fiscal periods, or...
25 July 1989 T.I. (Dec. 89 Access Letter, ¶1064)
A corporation's first fiscal period cannot exceed 53 x 7, or 371, days, from the date of incorporation.
27 July 1989 T.I. (Dec. 89 Access Letter, ¶1065)
Where a corporation had adopted a fiscal period ending June 30 and proposes to change its year-end for financial reporting purposes to September...