Cases
Fiducie financière Satoma v. Canada, 2018 FCA 74
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit | tax benefit to trust from tax-free dividend even though not distributed to a beneficiary | 265 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | using ss. 75(2) and 112(1) for tax-free dividends to trust thwarted s. 112(1) object to tax earnings when ultimately distributed | 299 |
| Tax Topics - Statutory Interpretation - Double Taxation (Presumption Against) | inclusion of income in more than one taxpayer’s hands is contrary to s. 3 | 161 |
| Tax Topics - Income Tax Act - Section 112 - Subsection 112(1) | abusive to use s. 112(1) so as to avoid ultimate taxation of individuals | 168 |
| Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | use of s. 75(2) to access s. 112(1) deduction for dividend in fact received by family trust, was abusive | 257 |
Bellingham v. The Queen, 96 DTC 6075 (FCA)
Schwartz v. Canada, 96 DTC 6103, [1996] 1 SCR 254
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R. v. Fogazzi, 92 DTC 6421 (Ont. C.J. (G.D.)), rev'd 93 DTC 5183 (Ont. CA)
Canada v. Fries, 90 DTC 6662, [1990] 2 S.C.R. 1322
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 36 |
The Queen v. McLaren, 90 DTC 6566 (FCTD)
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| Tax Topics - Income Tax Act - Section 63 - Subsection 63(2) | 24 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 37 |
Laxton v. The Queen, 89 DTC 5327 (FCA)
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| Tax Topics - Income Tax Act - Section 96 | 68 |
The Queen v. Cranswick, 82 DTC 6073, [1982] CTC 69 (FCA)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | 56 | |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 101 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 101 |
The Queen v. Atkins, 76 DTC 6258, [1976] CTC 497 (FCA)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | damages for termination of employment contract were not received under the contract | 54 |
Curran v. Minister of National Revenue, 59 DTC 1247, [1959] S.C.R. 850
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) | 57 |
See Also
Robinson v. The Queen, 2019 TCC 181 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures | pre-incorporation expenses incurred in developing e.g., a patent portfolio for drop down to a corporation were capital expenditures | 205 |
Smith v. The Queen, 2018 TCC 61 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(4) | RPP contribution deductible only from employment income rather than income generally | 282 |
| Tax Topics - Statutory Interpretation - Headings | heading provided guidance on the overall framework | 221 |
Henco Industries Limited v. The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192
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| Tax Topics - General Concepts - Evidence | parol evidence rule not applying to surrounding evidence/press releases admitted | 227 |
| Tax Topics - General Concepts - Fair Market Value - Land | deference to taxpayer's figure within appraiser's range of values | 105 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | compensation received in course of business but not in course of earning income | 184 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital | payment to withdraw from business was not an eligible capital amount | 138 |
| Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) | land ceased to be inventory through sterilization rather than business cessation | 176 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | compensation payment for destroyed business was non-taxable | 163 |
Malo v. The Queen, 2012 DTC 1214 [at 3588], 2012 TCC 75 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter | 113 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 98 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | 98 |
Kelly v. The Queen, 2012 DTC 1109 [at 3055], 2012 TCC 66
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| Tax Topics - General Concepts - Evidence | 152 | |
| Tax Topics - Statutory Interpretation - Business Judgment | 99 |
Ruff v. The Queen, 2012 TCC 105
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| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | 88 | |
| Tax Topics - Income Tax Act - Section 67 | 80 |
Lyncorp International Ltd. v. The Queen, 2010 DTC 1351 [at 4335], 2010 TCC 532, aff'd 2012 DTC 5032 [at 6684], 2011 FCA 352
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| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) | 161 |
Humphrey v. The Queen, 2006 DTC 2730, 2006 TCC 168 (Informal Procedure)
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| Tax Topics - General Concepts - Estoppel | 41 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 180 | |
| Tax Topics - Income Tax Act - Section 67 | 106 |
Fortino v. The Queen, 97 DTC 55 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)
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Abrahamson v. MNR, 91 DTC 213 (TCC)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | 94 | |
| Tax Topics - Income Tax Act - Section 254 | 119 |
Bray v. Best, [1989] BTC 102, [1989] UKHL TC_61_705 (HL)
The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)
Dorfman v. M.N.R., 72 DTC 6231 (FCTD)
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| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 83 |
Administrative Policy
19 March 2019 External T.I. 2018-0748731E5 - Taxation of Settlement Amounts
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | award received by unionized employees based on an unfair labour practice of their employer was not referable to lost remuneration | 76 |
29 July 2015 External T.I. 2015-0575631E5 - social assistance
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) | potential exclusion of payments in kind | 276 |
| Tax Topics - Income Tax Regulations - Regulation 233 - Subsection 233(2) | potential exclusion of payments in kind | 245 |
18 February 2013 Internal T.I. 2013-0477821I7 F - Montants forfaitaires - XXXXXXXXXX
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S2-F1-C2 - Retiring Allowances
28 November 2014 Internal T.I. 2014-0531221I7 F - Montants forfaitaires accordés aux témoins
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2 October 2014 External T.I. 2013-0491411E5 F - Allocation pour une automobile
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) | compensation for providing car rides not received in course of employment | 132 |
S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | repayment of embezzlement/losses from theft | 470 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | timing of deduction for loss from theft or embezzlement | 126 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | bad debt from fraudulent investment scheme | 77 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 266 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 150 | |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(f) | 284 | |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 193 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | voluntary payments | 67 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(c) | 134 |
2013 Ruling 2012-0464921R3 - Payment in lieu of continued PHSP coverage
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27 January 2012 External T.I. 2011-0421551E5 F - Pompiers volontaires
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| Tax Topics - Income Tax Act - Section 118.06 - Subsection 118.06(1) | “volunteer” firefighters are not true volunteers | 171 |
18 October 2011 External T.I. 2011-0394041E5 F - Fiducie personnelle- revenu brut
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Gross Revenue | gross revenue from farming business did not include capital gains | 101 |
IT-232R3 "Losses - Their Deductibility in the Loss Year or in Other Years"
24 June 1992 External T.I. 5-920948 -
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss | 204 |
91 C.R. - Q.44
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| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(k) | 14 |
2 October 1991 T.I. (Tax Window, No. 10, p. 20, ¶1493)
20 April 1990 T.I. (September 1990 Access Letter, ¶1404)
20 April 1990 TI 5-9269
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss | 75 |
1989 Canadian Petroleum Taxes Society Roundtable, Q. 4
89 CPTJ - Q4
Forms
Form T776 - Statement of Real Estate Rentals
Articles
Joel A. Nitikman, "Reasonable Expectation of Profit - Where Are We Now?", Business Vehicle, Vol IV, No. 3, 1998, p. 204.
Business Source/Reasonable Expectation of Profit
Commentary
Cases
Renaud v. Canada, 2019 CAF 154
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Ludmer v. Attorney General of Canada, 2018 QCCS 3381
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | recurring fee reduction amounts received for no work were income and taxable under s. 56(2) when directed to controlled company | 275 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | nature of the legal advice relied upon was unclear | 405 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | improper advancing of “settlement” elements that were not sustainable | 43 |
| Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) | equity-linked notes held in BVI company were portfolio investments held with a tax avoidance purpose, but were not subject to 7000(2)(d) interest accrual | 540 |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) | mere possibility of locking in value accretion each year did not crystallize the maximum amount of interest respecting the year | 454 |
| Tax Topics - General Concepts - Negligence and Fiduciary Duty | damages awarded against CRA for inter alia making unreasonable reassessments | 252 |
Radonjic v. Canada Revenue Agency, 2013 DTC 5152 [at 6352], 2013 FC 916
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Canada v. Johnson, 2013 DTC 5004 [at 5515], 2012 FCA 253
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | failure to seek confirmatory independent advice | 196 |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | taxable gains from contract with Ponzi operator | 249 |
Tarascio v. Canada, 2012 DTC 5046 [at 6785], 2012 FCA 30
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Vankerk v. Canada, 2006 FCA 96
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Hammill v. Canada, 2005 DTC 5397, 2005 FCA 252
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 61 | |
| Tax Topics - Income Tax Act - Section 67 | 102 |
McClelland v. Canada, 2004 DTC 6019, 2003 FCA 483
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Nadoryk v. Canada, 2003 DTC 5744, 2003 FCA 458
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Maysky v. Canada (Attorney General), 2003 DTC 5337, 2003 FCA 237
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Jarquio v. Canada, 2003 DTC 5164, 2003 FCA 80 (FCA)
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Titus v. Canada, 2003 DTC 5158, 2003 FCA 78 (FCA)
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Morris v. Canada, 2003 DTC 5236, 2003 FCA 116 (FCA)
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Partridge v. Canada, 2003 DTC 5175, 2003 FCA 91 (FCA)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 52 |
Mendoza v. Canada, 2003 DTC 5071, 2003 FCA 17 (FCA)
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Walls v. Canada, 2002 DTC 6960, 2002 SCC 47, [2002] 2 S.C.R. 684
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Stewart v. Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 S.C.R. 645
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | not tainted by capital gains motivation | 103 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 87 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Personal or Living Expenses | 10 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | avoid judicial rule-making | 72 |
Carter v. The Queen, 2001 DTC 5560, 2001 FCA 275 (FCA)
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Keeping v. Canada, 2001 DTC 5358, 2001 FCA 182 (FCA)
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Devito v. Canada (Attorney General), 2001 DTC 5394, 2001 FCA 166 (FCA)
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King v. Canada, 2001 DTC 5116 (FCA)
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Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39
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| Tax Topics - General Concepts - Onus | 95 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 104 |
Kuhlmann v. Canada, 98 DTC 6652 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 96 |
Mohammad v. The Queen, 97 DTC 5503 (FCA)
The Queen v. Donnelly, 97 DTC 5499 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 78 |
Watt Estate v. The Queen, 97 DTC 5459 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 102 |
Attorney General of Canada v. Mastri, 97 DTC 5420 (FCA)
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| Tax Topics - General Concepts - Stare Decisis | 77 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 136 |
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336
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Schwartz v. Canada, 96 DTC 6103, [1996] 1 SCR 254
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The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065 (FCA)
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Tonn v. The Queen, 96 DTC 6001 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expenses must be incurred within business framework | 64 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 146 |
Yaki v. The Queen, 94 DTC 6637 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 88 |
Landry v. The Queen, 94 DTC 6624 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 145 |
McGovern v. The Queen, 94 DTC 6527 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 146 |
Engler v. The Queen, 94 DTC 6280 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 165 | |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | channels expense deductions | 85 |
Johnson v. The Queen, 93 DTC 5462 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 42 |
DesChênes v. The Queen, 93 DTC 5234 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 80 |
Edwardes v. The Queen, 91 DTC 5635 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 50 |
Blake v. The Queen, 91 DTC 5574 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 38 |
Bigelow v. The Queen, 90 DTC 6262 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 100 |
The Queen v. Demers, 90 DTC 6216 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 87 |
McNeill v. The Queen, 89 DTC 5516 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 46 |
Posno v. The Queen, 89 DTC 5423 (FCTD)
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(4) | 32 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 126 |
Madronich v. The Queen, 89 DTC 5093 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 68 |
Coupland v. The Queen, 88 DTC 6251, [1988] 1 CTC 414 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 63 |
Chequer v. The Queen, 88 DTC 6169, [1988] 1 CTC 257 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 39 |
The Queen v. Gorjup, 87 DTC 5348, [1987] 2 CTC 129 (FCTD)
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| Tax Topics - General Concepts - Evidence | 61 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 132 |
London Life Insurance Co. v. The Queen, 87 DTC 5312, [1987] 2 CTC 90 (FCTD), aff'd 90 DTC 6001 (FCA)
Magee v. The Queen, 87 DTC 5282, [1987] 2 CTC 17 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 103 |
Meech v. The Queen, 87 DTC 5251, [1987] 1 CTC 421 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 94 |
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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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 98 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | fees for expansion of portfolio | 127 |
Croutch v. The Queen, 86 DTC 6453, [1986] 2 CTC 246 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 69 |
Gillis v. The Queen, 78 DTC 6103, [1978] CTC 44 (FCTD)
Moldowan v. The Queen, 77 DTC 5213, [1977] CTC 310, [1978] 1 S.C.R. 480
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 98 | |
| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 74 |
Tobias v. The Queen, 78 DTC 6028, [1978] CTC 113 (FCTD)
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See Also
Agence du revenu du Québec v. Weaver, 2019 QCCA 1687
Savage v. The Queen, 2017 TCC 247 (Informal Procedure)
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Abenaim v. The Queen, 2017 CCI 223
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | amount received by a terminated employee (claiming oppression) exceeding 18 months’ salary was non-taxable | 456 |
Mazo v. The Queen, 2016 TCC 232 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | pyramid scheme gives rise to business, not property, income | 275 |
| Tax Topics - Income Tax Act - Section 9 - Timing | revenue earned when credited to taxpayer's account with promoter | 208 |
Berger v. The Queen, 2015 TCC 153 (Informal Procedure)
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Hakki v. Secretary of State for Work and Pensions & Anor, [2014] BTC 22, [2014] EWCA Civ 530
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | careful and successful poker playing was not a trade or business | 124 |
Roszko v. The Queen, 2014 DTC 1083 [at 3099], 2014 TCC 59
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Evidence | finding of fraud by securities commission is a legal conclusion, not a factual allegation | 98 |
Garber v. The Queen, 2014 DTC 1045 [at 2812], 2014 TCC 1
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | title not held by GP on behalf of partnership | 118 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expenses mere window-dressing | 131 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | no source required if reasonable expectation of income | 225 |
| Tax Topics - Income Tax Act - Section 96 | GP had fraudulent intention | 235 |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | asset was mere window-dressing | 142 |
Drouin v. The Queen, 2014 DTC 1016 [at 2564], 2013 TCC 139
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Onus | late disclosure of assumptions does not reverse onus | 118 |
Bouchard v. The Queen, 2013 DTC 1203 [at 1083], 2013 TCC 247 (Informal Procedure)
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Kuhlmann v. The Queen, 2011 DTC 1297 [at 1675], 2011 TCC 410 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 84 |
Hanna v. The Queen, 2011 DTC 1279 [at 1584], 2011 TCC 382 (Informal Procedure)
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Perreault v. The Queen, 2011 DTC 1256 [at 1469], 2011 TCC 270 (Informal Procedure)
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Cohen v. The Queen, 2011 DTC 1195 [at 1080], 2011 TCC 262
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Dickson v. The Queen, 2011 DTC 1123 [at 681], 2011 TCC 153 (Informal Procedure)
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Daoust v. The Queen, 2010 DTC 1331 [at 4265], 2010 TCC 330 (Informal Procedure)
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Landriault v. The Queen, 2009 DTC 1334, 2009 DTC 1243, 2009 TCC 378 (Informal Procedure)
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Saint-Laurent v. The Queen, 2008 DTC 3668 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 103 |
Caputo v. The Queen, 2008 DTC 3596, 2008 TCC 263
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Copyright and Licences | 24 |
Allard v. The Queen, 2007 DTC 1667, 2005 TCC 91 (Informal Procedure)
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Coome v. The Queen, 2007 DTC 1522, 2007 TCC 493 (Informal Procedure)
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Leblanc v. The Queen, 2007 DTC 307, 2006 TCC 680
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 149 | |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | compulsive gamblers rather than professionals | 149 |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 149 |
Partridge v. The Queen, 2004 TCC 471 (Informal Procedure)
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Shaughnessy v. The Queen, 2002 DTC 1272 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 56 | |
| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) | 92 |
Rikley v. The Queen, 2001 DTC 756 (TCC)
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Allen v. The Queen, 99 DTC 968 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 140 |
Witkin v. The Queen, 98 DTC 1933 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 101 | |
| Tax Topics - Income Tax Act - Section 96 | 68 |
Balanko v. MNR, 88 DTC 6228, [1988] 1 CTC 317 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 45 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 41 |
Hawkes v. The Queen, 97 DTC 1258 (TCC)
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Heier v. The Queen, 97 DTC 739 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 90 |
Griffin v. The Queen, 96 DTC 1731 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 61 |
Heenan v. The Queen, 96 DTC 1344 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 89 |
Roopchan v. The Queen, 96 DTC 1338 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 151 |
Mattison v. The Queen, 95 DTC 489 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 79 |
Administrative Policy
29 March 2012 Internal T.I. 2011-0430871I7 F - Participation à une étude de recherche clinique
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | "volunteers" for drug clinical trials earned business rather than employment income | 24 |
10 April 2012 Internal T.I. 2011-0430291I7 F - Montant d'aide versé par la SAAQ à un conjoint
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S4-F11-C1 - Meaning of Farming and Farming Business
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | 253 | |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | 199 |
26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | criteria for determining whether a home is a principal place of business | 152 |
12 February 2015 External T.I. 2014-0550771E5 F - Allocation à des bénévoles - chantier particulier
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | mission work volunteers foregoing allowances | 96 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | quite unrepresentative remuneration: exempt | 98 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) | mission work under 2 years in LDCs | 97 |
3 October 2014 Internal T.I. 2014-0532051I7 - Rent and Part XIII Tax
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | non-commercial arrangement not subject to s. 247 but is subject to Part XIII/property taxes included in rent/no Part XII tax on imputed rent | 233 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | non-commercial arrangement not subject to s. 247 | 87 |
2 July 2014 Ministerial Correspondence 2014-0537231M4 - Local Exchange Trading System
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25 April 2014 External T.I. 2013-0485421E5 - Payments to Spouse for Attendant Care
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3 April 2014 External T.I. 2013-0512371E5 F - Qualification des montants gagnés au jeu de poker
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28 March 2014 External T.I. 2014-0525191E5 - Virtual Currencies (Bitcoins)
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4 March 2014 External T.I. 2013-0491981E5 F - Soins à un conjoint inapte
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Income Tax Technical News, No. 16, 8 March 1999
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Income Tax Technical News, No. 16, 8 March 1999
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6 July 2012 Internal T.I. 2012-0453461I7 F - rental losses Canada-France Treaty
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| Tax Topics - Treaties - Income Tax Conventions - Article 24 | s. 126(1) FTC re French income tax on rental income | 80 |
18 September 2012 External T.I. 2012-0442581E5 F - Fiducie au profit d'un athlète amateur
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| Tax Topics - Income Tax Act - Section 143.1 - Subsection 143.1(2) | amounts distributed from athlete trust were business income | 117 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expenses of athlete with athlete trust | 118 |
11 December 1998 TI 982864
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 39 |
28 May 1990 T.I. (October 1990 Access Letter, ¶1446)
October 1989 Revenue Canada Round Table - Q. 2 (Jan. 90 Access Letter, ¶1075)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 71 |
IT334R2 "Miscellaneous receipts" 1 January 1995
87 C.R. - Q.35
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 27 |
84 C.R. - Q.75
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 17 |
Articles
Benjamin Alarie, "The Taxation of Winnings from Poker and Other Gambling Activities in Canada", 2011 Canadian Tax Journal, Vol 59, p. 731, at p. 757
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| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 44 |
John Saunders, "The Empire Strikes Back - The Rebirth of the Reasonable Expectation of Profit Test", 2003 British Columbia Tax Conference Report.
Joel A. Nitikman, "Reasonable Expectation of Profit - Where Are We Now?", Canadian Current Tax, Vol 8, No. 8, May 1998, p. 81.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 0 |
John R. Owen, "The Reasonable Expectation of Profit Test: Is There a Better Approach?", 1996 Canadian Tax Journal, Vol. 44, No. 4, p. 979. [cited in the Hickman Motors case, supra, at p. 5373].
| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 0 |
Silver, "Great Expectations: Are They Reasonable?", 1995 Corporate Management Tax Conference Report, c. 6.
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Reasonable Expectation of Profit | 0 |
Commentary
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