Taxpayer

Table of Contents

Cases

Cristofaro v. Agence du revenu du Québec, 2020 QCCQ 1461, rev'd  2021 QCCA 1025

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Tax Topics - Income Tax Act - Section 118.9 a non-resident with no sources of income in Quebec nonetheless could transfer a tax credit to a Quebec taxpayer 434

R. v. Loosdrepht, 2009 DTC 6088 (BC Prov. Ct.)

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Doyle v. MNR, 89 DTC 5483, [1989] 2 CTC 270 (FCTD)

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The Queen v. Merali, 88 DTC 6173, [1988] 1 CTC 320 (FCA)

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Oceanspan Carriers Ltd. v. The Queen, 87 DTC 5102, [1987] 1 CTC 210 (FCA)

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Words and Phrases
taxpayer

Gordon v. The Queen, 86 DTC 6426, [1986] 2 CTC 280 (FCTD), aff'd 89 DTC 5481 (FCA)

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Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) 147

Lea-Don Canada Limited v. Minister of National Revenue, 70 DTC 6271, [1971] S.C.R. 95

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See Also

Marino v. The Queen, 2020 TCC 50 (Informal Procedure)

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Words and Phrases
taxpayer
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(b) tuition paid prior to becoming subject to tax under Part I was not to be recognized under s. 118.5(1)(b) 455
Tax Topics - Income Tax Act - Section 250.1 - Paragraph 250.1(a) s. 250.1 applies only to persons who would not be taxpayers under Oceanspan 276

King George Hotels Ltd. v. MNR, 68 DTC 635 (TAB)

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Administrative Policy

23 July 1996 External T.I. 9602225 - DISTRIBUTION OF PROPERTY BY A NON-RESIDENT TRUST

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18 January 1993 External T.I. 5-921718 -

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(4) 127

23 September 1991 Memorandum (Tax Window, No. 8, p. 22, ¶1429)

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IT-176R2 "Taxable Canadian Property - Interest in and Options on Real Property and Shares"

84 C.R. - Q.16

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) 24

Articles

Segal, "Dispositions of Interest in and Options on Real Property and Shares by Non-Residents of Canada", 1994 Canadian Tax Journal, Vol. 42, No. 2, p. 327

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