Subsection 4(1) - Income or loss from a source or from sources in a place
Administrative Policy
7 June 2017 CPTS Roundtable, 2017-0695131C6
Although CRA noted that the determination of whether a person is carrying on a single business or multiple separate businesses is a question of...
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | Q.1 - Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis | 213 |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Canadian Resource Property - Paragraph (d) | Q.2 - a Canadian resource royalty interest requires a right to “take production” | 135 |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them | 193 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | Q.4 - by analogy to mining, hydrocarbons may be similar properties | 348 |
| Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) | Q.5 - normal course dispositions of oil and gas properties generally are not of a separate business | 131 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 26 | Q.7 - refinery catalysts are Class 26 property | 87 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 49 | Q.8 - taxpayers generally have the documentary evidence on hand to allocate costs between pipelines and pipeline appendages | 117 |
Paragraph 4(1)(a)
Cases
Dupont Canada Inc. v. Canada, 2001 DTC 5269, 2001 FCA 114
A sale by the taxpayer, a manufacturer, of most of the assets of its explosives manufacturing operation in Nipissing was found not to be a sale of...
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| Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) | 155 |
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336, [1998] 1 CTC 213
The taxpayer, which at all relevant times had been engaged in the leasing of cars and trucks, received on the winding-up of its subsidiary heavy...
Engler v. The Queen, 94 DTC 6280, [1994] 2 CTC 64 (FCTD)
Before going on to find that the taxpayer had a reasonable expectation of profit with respect to one of his businesses for only one of the...
Gulf Canada Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen and Gulf Canada Resources Ltd. [previously Gulf Oil Canada Ltd.] v. Her Majesty The Queen, 90 DTC 6622, [1991] 1 CTC 99 (FCTD), aff'd 93 DTC 6123 (FCA)
It was found that ss.124.1 and 124.2 established specific rules for computing income which related to production, and that the general "income...
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| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 47 |
Macmillan Bloedel Ltd. v. The Queen, 90 DTC 6219, [1990] 1 CTC 468 (FCTD)
Interest on employee advances, overdue trade accounts, loans to customers, and working capital advances to subsidiaries, gave rise to income from...
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| Tax Topics - General Concepts - Accounting Principles | 16 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | loss on forward contract to lock in Canadian dollar cost of U.S.-dollar borrowing was issue expense | 191 |
| Tax Topics - Income Tax Regulations - Regulation 700 - Subsection 700(1) | 118 |
Pe Ben Industries Co. Ltd. v. The Queen, 88 DTC 6347, [1988] 2 CTC 120 (FCTD)
An operation of trucking goods and materials from a railway yard to a Syncrude plant pursuant to a 5-year contract was held to be a separate...
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| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital | 109 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | contractual right was a property right or chose in action | 93 |
| Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition | 150 | |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | compensation for loss of business line | 79 |
Excelsior Life Insurance Co. v. The Queen, 85 DTC 5164, [1985] 1CTC 213 (FCTD)
An argument of the Crown, that segregated funds and non-segregated funds of life insurers are to be equated with "sources" of income under s....
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| Tax Topics - Statutory Interpretation - Scheme | 42 |
Klie v. The Queen, 81 DTC 5061, [1981] CTC 154 (FCTD)
Rentals which a farmer obtained by leasing shorefront lands to tenants who built cottages on those lands, were held to be receipts from his...
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| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 62 |
The Queen v. Dorchester Drummond Corp. Ltd., 79 DTC 5163, [1979] CTC 219 (FCTD)
Semble, that the making of loans and the derivation of revenues from land constituted a single business of the taxpayer company.
Randall v. Minister of National Revenue, 67 DTC 5151, [1967] CTC 236, [1967] S.C.R. 484
The management by the taxpayer and his brother of horse racing activities at tracks in Vancouver and Portland, Oregon were found to be one...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) | 68 |
Interprovincial Pipe Lane Co. v. Minister of National Revenue, 59 DTC 1229, [1959] CTC 339, [1959] S.C.R. 763
Before finding that s. 127(1)(av) of the 1948 Act did not apply to require the deduction of interest on general corporate borrowings of the...
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | corporate-level borrowing did not relate to investment in sub | 209 |
Canadian Kodak Sales Ltd. v. MNR, 54 DTC 1194, [1954] CTC 375 (Ex Ct)
The taxpayer, whose business was to purchase photographic equipment from affiliates and sell them to customers, in 1940 acquired the business of...
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment | 116 |
See Also
Pavages Vaudreuil Ltée v. Agence du revenu du Québec, 2021 QCCQ 3890
In addition to being involved in construction (maintenance of roads, streets and bridges), the taxpayer owned several natural gravel quarries and...
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| Tax Topics - Income Tax Regulations - Regulation 1104 - Subsection 1104(9) - Paragraph 1104(9)(e) | operation of washing, sorting and crushing aggregate was separate from operation of extracting the aggregate | 264 |
| Tax Topics - Income Tax Regulations - Regulation 1104 - Subsection 1104(9) - Paragraph 1104(9)(c) | operation of washing, sorting and crushing aggregate was separate from a road construction operation in which 27% of the product was used | 263 |
Ferme Lunick Inc. v. Agence du revenu du Québec, 2020 QCCQ 1703
The taxpayer operated a four-employee 1500-acre farm that produced potatoes, grains, market garden and dairy products, as well as a 10+-employee...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (a) | potato sorting, cleaning and bagging operation was integrated with the farm on which it was housed | 321 |
Coop de travailleurs en serres Belle-de-Jour v. Agence du revenu du Québec, 2019 QCCQ 6609
The taxpayer used approximately 20% of the area within greenhouses to grow cucumbers or other vegetables, or flowers, from seed for sale as...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | greenhouse heating equipment was used in non-farming manufacturing of floral arrangements | 414 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | use of greenhouses to further grow flowers before use in making floral arrangements did not constitute farming | 163 |
Atlantic Packaging Products Ltd. Atlantic Produits D'Emballage Ltée v. The Queen, 2018 TCC 183, aff'd 2020 FCA 75
The taxpayer, a paper products manufacturer, engaged in a hybrid transaction in which it sold some of the assets of its “Tissue Division”...
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| Tax Topics - Income Tax Act - Section 54.2 | s. 54.2 did not apply to the drop-down of under 68% of the assets of a business division to a Newco for Newco shares | 710 |
Leekes Ltd v HM Revenue & Customs, [2018] EWCA Civ 1185
A British taxpayer (Leekes) carrying on a retail trade through four stores acquired, for nominal consideration, all the shares of another company...
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) - Subparagraph 111(5)(a)(ii) | ability of successor to apply predecessor losses to income from same trade did not extend to profits from an enlarged trade | 457 |
Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3
The Crown brought a motion under Rule 58(1) for determination of questions of law respecting the application of Art. XXII(2) of the Canada-Brazil...
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| Tax Topics - Treaties - Income Tax Conventions - Article 24 | Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income | 594 |
| Tax Topics - Treaties - Income Tax Conventions | OECD commentaries applied to Brazil (not an OECD member) | 231 |
Kruger Incorporated v. The Queen, 2015 DTC 1127 [at 788], 2015 TCC 119, rev'd 2016 FCA 186
The taxpayer ran, along with its subsidiaries, a lumber and paper goods business with annual sales of approximately $2.5 billion. In response to...
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| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | options contracts purchased, but not those written, were inventory | 200 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | options contracts purchased, but not those written, were inventory | 122 |
| Tax Topics - Income Tax Act - Section 9 - Timing | realization principle applied to FX options written by taxpayer | 307 |
Ruff v. The Queen, 2012 TCC 105
The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with...
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| Tax Topics - Income Tax Act - Section 3 | 92 | |
| Tax Topics - Income Tax Act - Section 67 | 82 |
CAE Inc. v. The Queen, 2011 DTC 1362 [at 2031], 2011 TCC 354, aff'd 2013 DTC 5084 [at 5944], 2013 FCA 92
The taxpayer manufactured flight simulators which it used to provide flight training services directly or which were leased by it to airlines for...
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| Tax Topics - General Concepts - Stare Decisis | 205 |
Dubois c. La Reine, 2007 DTC 1534, 2007 TCC 461 (Informal Procedure)
Before going on to find that legal fees incurred as a result of a cancellation by the taxpayer of an agreement to purchase a building were capital...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 100 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation | 94 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | legal expenses incurred re cancellation of purchase may be loss from disposition | 90 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | disposition of right to acquire building | 122 |
Tinhorn Creek Vineyards Ltd. v. The Queen, 2005 TCC 693
In finding that the taxpayer’s winemaking was linked to viticulture and was an integral part of its (estate winery) farming business, Campbell J...
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| Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(b) | winemaking an integral part of viticulture operation | 239 |
The Queen v. London Life Insurance Co., 90 DTC 6001, [1990] 1 CTC 43 (F.C.A)
The taxpayer had excess computer capacity that was needed to meet peak demands of its life insurance business but not otherwise, and which it...
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| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 40 |
Re Seagrams Distillers (Ontario) Ltd. (1985), 54 OR (2d) 289 (Ont. D.C.)
The businesses of subsidiaries acting as sales organizations for their parent, a distiller, were found to be an integral part of that distilling...
River Estates Sdn. Bhd. v. Dir. Gen. of Inland Revenue, [1984] BTC 20 (PC)
Since there was some doubt as to whether or not a forestry operation and a tree plantation operation were separate businesses, it was not...
Re Aluminum Co. of Canada Ltd. (1984), 46 OR (2d) 614 (HC), aff'd 54 OR (2d) 249 (Ont. D.C.).
The business of one company does not embrace the business of a second company if the second company is not the agent or puppet of the first and is...
Gloucester Railway Carriage and Wagon Co., Ltd., [1925] AC 469, [1925] UKHL TC_12_720 (HL)
The taxpayer manufactured railway wagons, which it sold outright (outright or under hire purchase agreements) as well as letting out wagons on...
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment | 115 |
Administrative Policy
23 April 2019 Internal T.I. 2018-0750821I7 F - Revenu d’emploi d’un Indien
The employer is located on a reserve and carries on a construction business. In addition, the employer provides employee lease-out services as to...
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| Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 | employee lease-out servicing activity does not give rise to exempt income if only connection to reserve is employer residence | 258 |
2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F - Changement d'usage - duplex
The owner of a duplex consisting of two identical units occupies the first unit and rents out the second. Subsequently, he incurs significant...
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| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) | substantially renovating the personal-use portion of a rental property (without changing floor areas) generally would not engage the change-of-use rules | 243 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | duplex is single property | 51 |
22 September 2016 External T.I. 2015-0594721E5 F - Inventory of animal meat
Although it stated that the question of whether a processing operation was part of a farming business was a question of fact, CRA indicated that a...
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| Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(b) | processing meat can form part of a farming business | 225 |
S4-F11-C1 - Meaning of Farming and Farming Business
Separate v. same business
1.23 Where a taxpayer carries on a farm operation together with a non-farm operation, it is a mixed question of fact and...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | 353 | |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | 334 |
7 May 2014 Internal T.I. 2014-0528251I7 - Surface Rentals for Wind Farms
Would income received by a farmer for the rental of land to a wind farm developer for the purpose of constructing and operating a wind farm be...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | wind farm not a farm | 99 |
19 November 2013 External T.I. 2013-0510351E5 - Steel Tanks and Oak Barrels of a Winery Business
The taxpayer in 2013-0503311E5 carried on a wine-making business that involved both farming activities (i.e., growing grapes) and non-farming...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | wine fermentation not farming | 247 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | wine fermentation not processing | 174 |
| Tax Topics - Income Tax Regulations - Regulation 1104 - Subsection 1104(9) - Paragraph 1104(9)(a) | wine production not farming | 247 |
13 June 2012 External T.I. 2012-0440381E5 - Application of Income Tax Regulation 2602
Where a US-resident hockey player plays for a team that has a permanent establishment only in Ontario but he performs his duties of employment in...
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| Tax Topics - Income Tax Regulations - Regulation 2602 - Reg. 2602(1) | allocation to hockey venues | 62 |
29 February 2012 External T.I. 2012-0435151E5 - Installation of Solar Panels
Respecting the question as to whether income earned by an individual taxpayer from the sale of electricity generated from a solar photovoltaic...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.2 | 11 |
20 January 2010 Internal T.I. 2009-0348571I7 - Interest Rate Swaps and Resource Profits
a Canadian resource corporation in the ordinary course of business had borrowed under long-term financings and entered into interest rate swaps...
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| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1.1) | 174 |
27 August 2008 External T.I. 2008-0287951E5 F - Entreprises distinctes
A corporation operating a chain of boutique stores sells the assets of one such boutique including the customer list. Regarding whether this...
24 June 2005 External T.I. 2004-0109201E5 F - Professions libérales - Travaux en cours
Can a partnership make the s. 34 election where it carries on a single business but earns income from two types of activities, one of which is not...
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| Tax Topics - Income Tax Act - Section 34 | a professional partnership carrying on a secondary non-professional activity may make the election | 124 |
30 September 2004 Internal T.I. 2004-0083301I7 F - Entreprises distinctes
In finding that it was highly likely that the different centres owned by a corporation represented the same business, the Directorate noted that...
17 June 2004 External T.I. 2003-0045411E5 F - Entreprise de placement déterminée
Xco co-owns several rental properties (in the commercial sector) in co-ownership with other taxpayers with which it deals at arm's length and...
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| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business - Paragraph (a) | partnership business is transparent but separate from similar business carried on directly | 181 |
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business - Paragraph (b) | para. (b) may not apply where the SIB is carried on through a partnership | 276 |
17 July 1997 Internal T.I. 9700547 - DEDUCTION OF TERMINAL LOSS FROM RESOURCE PROFITS
The disposal of machinery would be considered as related and attributable to a mining business for purposes of ss.9 and 18(1)(a) even though such...
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| Tax Topics - Income Tax Regulations - Regulation 1206 - Subsection 1206(1) - Resource Activity | 30 |
88 CPTJ - Q.23
All amounts must be related to a source of income to be deductible under the Act. If there is no potential source of income, there is no deduction.
IT-206R "Separate Businesses" 1 January 1995
2. Whether the carrying on of two or more simultaneous business operations by a taxpayer is the same business is dependent upon the degree of...
Paragraph 4(1)(b)
See Also
Nonis v. The Queen, 2021 TCC 31
The taxpayer, Mr. Nonis, who was a U.S. resident, had been employed as the general manager of the Toronto Maple Leafs pursuant to an employment...
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| Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(c.1) | a U.S. resident avoided Canadian tax on employment income from a Canadian employer when he ceased performing active duties | 502 |
Administrative Policy
9 February 2012 External T.I. 2008-0280941E5 F - Foreign sourced income - transportation
Canco, which carries on a freight transportation business in Canada and the U.S., is subject to New York State franchise tax. CRA noted that in...
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| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | incidental business activities in jurisdiction may not constitute carrying on business there | 51 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(9) | s. 4(1)(b) applied for s. 126(9) purposes | 161 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax | NY franchise tax qualified as an income tax only if it was not based on non-income specified minimums | 238 |
3 November 2008 External T.I. 2008-0278431E5 F - Déménagement hors Canada du siège soc. de société
In the context of a general discussion of consequences where there was an acquisition of control of a corporation incorporated in Canada in 2005...
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| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | OECD Commentary informs allocation of sales through non-resident office to Cdn manufacturing operation | 172 |
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(5) | central management and control test overridden | 122 |
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Investment Tax Credit - Paragraph (a.1) | ITC potentially available to a non-resident corporation carrying on business in Canada | 97 |
Articles
Markovitz, "Permanent Establishment - Home Office Relations", International Tax Planning, 1996 Canadian Tax Journal, Vol. 44, No. 4, p. 112.
Subsection 4(2)
Administrative Policy
18 June 2015 External T.I. 2015-0578071E5 F - Reimbursement of overpayment of QPIP benefits
After becoming a non-resident of Canada, the taxpayer was required to repay excess benefits received by her in a previous year pursuant to the...
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| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(n) - Subparagraph 60(n)(v.1) | no s. 60 deductions if non-resident | 175 |
| Tax Topics - Other Legislation/Constitution - Federal - Financial Administration Act - Section 23 - Subsection 23(2) | general criteria for granting remission | 199 |
Subsection 4(3) - Deductions applicable
Cases
Interprovincial Pipe Line Company v. Minister of National Revenue, 68 DTC 5093, [1968] CTC 156, [1968] S.C.R. 498
The enactment of s. 139(1b) (now s. 4(3)) required the taxpayer to net related interest expense against interest income receivable by it from its...
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | s. 4(3) requires netting of interest expense | 62 |
Administrative Policy
S5-F2-C1 - Foreign Tax Credit
Provided that s. 4(3) is satisfied, "allocation of expenses to a source of gross income in a particular foreign country for financial statement...
Commentary
Where a taxpayer has a particular source of income, such as a business, s. 4(1)(a) requires among other things that the income from that source be...