Section 4

Subsection 4(1) - Income or loss from a source or from sources in a place

Paragraph 4(1)(a)

Commentary

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Cases

Dupont Canada Inc. v. Canada, 2001 DTC 5269, 2001 FCA 114

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Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Engler v. The Queen, 94 DTC 6280 (FCTD)

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Gulf Canada Ltd. v. The Queen, 90 DTC 6622 (FCTD), aff'd 93 DTC 6123 (FCA)

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Macmillan Bloedel Ltd. v. The Queen, 90 DTC 6219 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Accounting Principles 14
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 185
Tax Topics - Income Tax Regulations - Regulation 700 - Subsection 700(1) 116

Pe Ben Industries Co. Ltd. v. The Queen, 88 DTC 6347, [1988] 2 CTC 120 (FCTD)

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Excelsior Life Insurance Co. v. The Queen, 85 DTC 5164, [1985] 1CTC 213 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Scheme 38

Klie v. The Queen, 81 DTC 5061, [1981] CTC 154 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) 60

The Queen v. Dorchester Drummond Corp. Ltd., 79 DTC 5163, [1979] CTC 219 (FCTD)

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Randall v. Minister of National Revenue, 67 DTC 5151, [1967] CTC 236, [1967] S.C.R. 484

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Interprovincial Pipe Lane Co. v. Minister of National Revenue, 59 DTC 1229, [1959] CTC 339, [1959] S.C.R. 763

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) corporate-level borrowing did not relate to investment in sub 203

Canadian Kodak Sales Ltd. v. MNR, 54 DTC 1194 (Ex Ct)

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See Also

Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3

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Locations of other summaries Wordcount
Tax Topics - Treaties - Articles of Treaties - Article 24 Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income 552
Tax Topics - Treaties OECD commentaries applied to Brazil (not an OECD member) 209

Kruger Incorporated v. The Queen, 2015 DTC 1127 [at 788], 2015 TCC 119, rev'd 2016 FCA 186

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) options contracts purchased, but not those written, were inventory 188
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory options contracts purchased, but not those written, were inventory 114
Tax Topics - Income Tax Act - Section 9 - Timing realization principle applied to FX options written by taxpayer 293

Ruff v. The Queen, 2012 TCC 105

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CAE Inc. v. The Queen, 2011 DTC 1362 [at 2031], 2011 TCC 354, aff'd 2013 DTC 5084 [at 5944], 2013 FCA 92

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis 189

Tinhorn Creek Vineyards Ltd. v. The Queen, 2005 TCC 693

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(b) winemaking an integral part of viticulture operation 229

The Queen v. London Life Insurance Co., 90 DTC 6001 (F.C.A)

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Re Seagrams Distillers (Ontario) Ltd. (1985), 54 OR (2d) 289 (Ont. D.C.)

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River Estates Sdn. Bhd. v. Dir. Gen. of Inland Revenue, [1984] BTC 20 (PC)

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Re Aluminum Co. of Canada Ltd. (1984), 46 OR (2d) 614 (HC), aff'd 54 OR (2d) 249 (Ont. D.C.).

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Gloucester Railway Carriage and Wagon Co., Ltd., [1925] AC 469, [1925] UKHL TC_12_720 (HL)

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Administrative Policy

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F - Changement d'usage - duplex

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Locations of other summaries Wordcount
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 233
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property duplex is single property 45

22 September 2016 External T.I. 2015-0594721E5 F - Inventory of animal meat

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(b) processing meat can form part of a farming business 192

S4-F11-C1 - Meaning of Farming and Farming Business

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7 May 2014 Internal T.I. 2014-0528251I7 - Surface Rentals for Wind Farms

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming wind farm not a farm 97

19 November 2013 External T.I. 2013-0510351E5 - Steel Tanks and Oak Barrels of a Winery Business

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13 June 2012 External T.I. 2012-0440381E5 - Application of Income Tax Regulation 2602

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Tax Topics - Income Tax Regulations - Regulation 2602 - Reg. 2602(1) allocation to hockey venues 60

29 February 2012 External T.I. 2012-0435151E5 - Installation of Solar Panels

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Words and Phrases
incidental

20 January 2010 Internal T.I. 2009-0348571I7 - Interest Rate Swaps and Resource Profits

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17 July 1997 Internal T.I. 7-970054 -

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88 CPTJ - Q.23

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IT-206R "Separate Businesses" 1 January 1995

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Paragraph 4(1)(b)

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

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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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) s. 4(3) requires netting of interest expense 56

Administrative Policy