Cases
Bodine v. Canada, 2011 DTC 5084 [at 5840], 2011 FCA 157
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Canada Safeway Limited v. Canada, 2008 FCA 24
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318806 B.C. Ltd. v. Canada, 2006 DTC 7403, 2002 FCA 353 (FCA)
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Bell v. Canada, 2002 DTC 6780, 2002 FCA 7
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 53 |
Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 99 | |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | 85 |
Roseland Farms Ltd. v. Canada, 99 DTC 5704 (FCTD), aff'd 2001 DTC 5392 (FCA), 2001 FCA 167
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| Tax Topics - General Concepts - Purpose/Intention | 94 |
Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 130 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | 107 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | interest-free advances to US sub by developer | 33 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | interest-free advances made only re loss protection | 47 |
Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103
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|---|---|---|
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | loss recognized on decline in value of land held as an adventure | 142 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | property held in an adventure was inventory | 83 |
| Tax Topics - Statutory Interpretation - Certainty | 97 | |
| Tax Topics - Statutory Interpretation - Drafting Style | 95 | |
| Tax Topics - Statutory Interpretation - Inserting Words | 104 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 80 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 97 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | s. 10(1) applied to an adventure in the nature of trade even if that deemed business was not “carried on” | 75 |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | property not generating income does not convert to capital property unless s. 13(7) or 45(1) applies | 209 |
Leasehold Construction Corp. v. The Queen, 95 DTC 5470 (FCTD)
Kaneff Properties Ltd. v. The Queen, 95 DTC 5345 (FCTD)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | gain from when commenced developing as commercial office tower was capital gain | 160 |
Iula v. The Queen, 94 DTC 6614 (FCTD)
Bellingham v. The Queen, 94 DTC 6564 (FCTD)
Rivermede Developments Ltd. v. The Queen, 93 DTC 5365 (FCTD)
Lee v. The Queen, 92 DTC 6067 (FCTD)
Breakell v. The Queen, 91 DTC 5419 (FCTD)
Witten v. The Queen, 91 DTC 5041 (FCTD)
Snell Farms Limited v. Her Majesty the Queen, 90 DTC 6693, [1991] 1 CTC 5 (FCTD)
Homes Development Ltd. v. The Queen, 90 DTC 6654 (FCTD)
King Edward Hotel (Calgary) Ltd. v. The Queen, 90 DTC 6468 (FCTD)
W. Hanley & Co. Ltd. v. The Queen, 90 DTC 6354 (FCTD)
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| Tax Topics - General Concepts - Onus | 148 |
Hertel v. The Queen, 90 DTC 6341 (FCTD)
Grouchy v. The Queen, 90 DTC 6267 (FCTD)
O&M Investments Ltd. v. The Queen, 90 DTC 6150 (FCTD)
Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180 (FCTD)
Crystal Glass Canada Ltd. v. The Queen, 89 DTC 5143 (FCA)
Mintenko v. The Queen, 88 DTC 6537, [1989] 1 CTC 40 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 59 | |
| Tax Topics - Income Tax Act - Section 44 - Subsection 44(1) | 34 | |
| Tax Topics - Income Tax Act - Section 54 - Principal Residence | 87 |
Sardo v. The Queen, 88 DTC 6464, [1988] 2 CTC 290 (FCTD)
R. v. Landes, [1988] 1 CTC 124 (Queb. Ct. S.P.)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 63 | |
| Tax Topics - Income Tax Act - Section 242 | 25 |
Independent Gaz Service Inc. v. The Queen, 88 DTC 6230, [1988] 1 CTC 309 (FCTD)
Johnstone v. The Queen, 88 DTC 6032, [1988] 1 CTC 48 (FCTD)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 70 |
Desrocher Development Corp. v. The Queen, 87 DTC 5363, [1987] 2 CTC 124 (FCTD)
Magilb Development Corp. Ltd. v. The Queen, 87 DTC 5012, [1987] 1 CTC 66 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 35 | |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | preliminary overtures for approval of housing development of farm did not convert to inventory | 204 |
Hebert v. The Queen, 86 DTC 6543, [1986] 2 CTC 123 (FCTD)
Happy Valley Farms Ltd. v. The Queen, 86 DTC 6421, [1986] 2 CTC 259 (FCTD)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 46 |
Biffis and Cappuccitti v. The Queen, 86 DTC 6403, [1986] 2 CTC 184 (FCTD)
Algonquin Enterprises Ltd. v. The Queen, 86 DTC 6233, [1986] 1 CTC 493 (FCTD), aff'd 90 DTC 6377 (FCA)
Future Investments Ltd. v. The Queen, 86 DTC 6224, [1986] 1 CTC 458 (FCTD)
Marsted Holdings Ltd. v. The Queen, 86 DTC 6200, [1986] 1 CTC 436 (FCTD)
Giannakos v. The Queen, 86 DTC 6145, [1986] 1 CTC 325 (FCTD)
Regina Shoppers Mall Ltd. v. The Queen, 86 DTC 6091, [1986] 1 CTC 261 (FCTD), aff'd 89 DTC 5482 (FCA)
Toolsie v. The Queen, 86 DTC 6117, [1986] 1 CTC 216 (FCTD)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 104 |
Jodare Ltd. v. The Queen, 86 DTC 6054, [1986] 1 CTC 250 (FCTD)
Jacobson Holdings Ltd. v. The Queen, 85 DTC 5634, [1986] 1 CTC 87 (FCTD)
Zen v. The Queen, 85 DTC 5531, [1985] 2 CTC 313 (FCTD)
First Investors Corp. Ltd. v. The Queen, 85 DTC 5343, [1985] 2 CTC 96 (FCTD), aff'd 87 DTC 5175 (FCA)
The Queen v. Bassani, 85 DTC 5232, [1985] 1 CTC 314 (FCTD)
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| Tax Topics - General Concepts - Onus | 23 |
Woodbine Developments Ltd. v. The Queen, 84 DTC 6556, [1984] CTC 616 (FCTD)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 408(1) | 73 |
H. Fine and Sons Ltd. v. The Queen, 84 DTC 6520, [1984] CTC 500 (FCTD)
W. Rudolph Construction Ltd. v. The Queen, 84 DTC 6454, [1984] CTC 457 (FCTD)
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| Tax Topics - General Concepts - Evidence | 37 |
Farmer Construction Ltd. v. The Queen, 84 DTC 6331, [1984] CTC 370 (FCTD)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 344(1) [Costs] | 23 |
Schneider v. The Queen, 84 DTC 6286, [1984] CTC 264 (FCTD), aff'd 86 DTC 6297, [1986] 2 CTC 89 (FCA) (sub nomine Mohawk Horning Ltd. v. The Queen)
Niemi v. The Queen, 84 DTC 6189, [1984] CTC 181 (FCTD)
Carsons Camps Ltd. v. The Queen, 84 DTC 6070, [1984] CTC 46 (FCTD)
Marois v. The Queen, 83 DTC 5344, 84 DTC 6157 (FCTD)
Sharon Mills Developments Ltd. v. The Queen, 83 DTC 5420, [1983] CTC 384 (FCTD)
McDonald v. The Queen, 83 DTC 5264, [1983] CTC 211 (FCTD), aff'd 87 DTC 5276 (FCA)
Belvedere Park Development Co. Ltd. v. The Queen, 83 DTC 5214, [1983] CTC 171 (FCTD)
Van Anrep v. The Queen, 81 DTC 5278, [1981] CTC 358 (FCTD), aff'd 83 DTC 5100, [1983] CTC 84 (FCA)
Gameroff v. The Queen, 83 DTC 5013, [1982] CTC 411 (FCTD), rev'd 86 DTC 6023, [1986] 1 CTC 169 (FCA)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 93 |
Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 30 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | 30 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | 28 |
Walton v. The Queen, 82 DTC 6220, [1982] CTC (FCTD)
Colville-Reeves v. The Queen, 82 DTC 6005, [1981] CTC 512 (FCTD)
South Shore Estates (Saltfleet) Ltd. v. The Queen, 81 DTC 5181, [1981] CTC 252 (FCTD)
Kit-Win Holdings (1973) Ltd. v. The Queen, 81 DTC 5030, [1981] CTC 43 (FCTD)
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| Tax Topics - General Concepts - Purpose/Intention | 39 | |
| Tax Topics - General Concepts - Onus | 116 |
Leduc v. The Queen, 81 DTC 5017, [1981] CTC 21 (FCTD)
The Queen v. Dumas, 80 D.T.C 6398, [1981] CTC (FCTD), rev'd 89 DTC 5004 (FCA)
Jarvie Holdings Ltd. v. The Queen, 80 DTC 6395, [1980] CTC 525 (FCTD)
Greenbranch Investments Ltd. v. The Queen, 80 DTC 6384, [1980] CTC 514 (FCTD)
Marshall v. The Queen, 80 DTC 6357, [1980] CTC 475 (FCTD)
Horvath v. The Queen, 80 DTC 6350, [1980] CTC 467 (FCTD)
Robbie Holdings Ltd. v. The Queen, 80 DTC 6336, [1980] CTC 422 (FCTD)
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| Tax Topics - General Concepts - Purpose/Intention | 82 |
Glacier Realties Ltd. v. The Queen, 80 DTC 6243, [1980] CTC 308 (FCTD)
Montford Lakes Estates Inc. v. The Queen, 79 DTC 5467, [1980] CTC 27 (FCTD)
Hummel Corp. of Quebec Ltd. v. The Queen, 79 DTC 5426, [1979] CTC 483 (FCTD)
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| Tax Topics - General Concepts - Evidence | 48 |
Gamble v. The Queen, 79 DTC 5397, [1979] CTC 463 (FCTD)
Caponecchia v. The Queen, 79 DTC 5364, [1979] CTC 445 (FCTD)
Kensington Land Developments Ltd. v. The Queen, 79 DTC 5283, [1979] CTC 367 (FCA)
Demeter Equity Ltd. v. The Queen, 79 DTC 5230, [1979] CTC 311 (FCTD)
Riznek Construction Ltd. v. The Queen, 79 DTC 5131, [1979] CTC 197 (FCTD)
Edmund Peachey Ltd. v. The Queen, 79 DTC 5064, [1979] CTC 51 (FCA)
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| Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) | 66 |
The Queen v. Greenington Group Ltd., 79 DTC 5026, [1979] CTC 31 (FCTD)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 252 |
Cohen v. The Queen, 78 DTC 6099, [1978] CTC 63 (FCTD), aff'd 80 DTC 6250, [1980] CTC 318 (FCA)
The Queen v. Randall Park Development Ltd., 78 DTC 6545, [1978] CTC 826 (FCTD)
Choice Realty Corp. v. The Queen, 78 DTC 6415, [1978] CTC 613 (FCTD)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | s. 20(1)(n) reserve not claimed in alternative until subsequent years was statute-barred | 140 |
| Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (d) | 71 |
Hiwako Investments Ltd. v. The Queen, 78 DTC 6281, [1978] CTC 378 (FCA)
Birmount Holdings Ltd. v. The Queen, 78 DTC 6254, [1978] CTC 358 (FCA)
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| Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) | 84 | |
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(4) | 130 |
The Queen v. Borinsky, 77 DTC 5389, [1977] CTC 570 (FCTD)
The Queen v. Froese, 77 DTC 5364, [1977] CTC 526 (FCTD)
Reicher v. The Queen, 76 DTC 6001, [1976] CTC 659 (FCA)
Fredericton Housing Ltd. v. The Queen, 75 DTC 5367, [1975] CTC 537 (FCA)
McDonald v. The Queen, 74 DTC 6644, [1974] CTC 836 (FCA)
Sikler v. The Queen, 73 DTC 5553, [1973] CTC 736 (FCTD)
Vaughan Construction Co. v. Minister of National Revenue, 70 DTC 6268, [1971] S.C.R. 55
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First Torland Investments Ltd. v. MNR, 69 DTC 5109, [1969] CTC 134 (Ex Ct), briefly aff'd 70 DTC 6354, [1970] CTC 634 (SCC)
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Words and Phrases
investingBalstone Farms Limited v. Minister of National Revenue, 68 DTC 5018, [1968] CTC 38, [1968] S.C.R. 205
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Moluch v. Minister of National Revenue, 66 DTC 5463 (Ex Ct)
Hazeldean Farm v. MNR, 66 DTC 5397, [1967] 1 Ex CR 245
Racine v. MNR, 65 DTC 5098 (Ex Ct)
Fraser v. Minister of National Revenue, 64 DTC 5224, [1964] CTC 372, [1964] S.C.R. 657
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | sale of shares was alternate means to realize gain from real estate dealing | 135 |
See Also
Polonovski v. Agence du revenu du Québec, 2020 QCCQ 8943
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | IT-218R preferred over CAE | 330 |
Ouellette v. Agence du revenu du Québec, 2020 QCCQ 8765
Hansen v. The Queen, 2020 TCC 102
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | no carelessness given bona fide belief that principal residence exemption applied | 178 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | benefit of doubt should be given to taxpayer | 252 |
Chevalier v. Agence du revenu du Québec, 2020 QCCQ 2220
Immeubles Zamora ltée v. Agence du revenu du Québec, 2020 QCCA 894
Bishara v. Agence du revenu du Québec, 2020 QCCA 854
Piché v. Agence du revenu du Québec, 2020 QCCQ 1283
Latulippe v. Agence du revenu du Québec, 2019 QCCA 2177
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| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | subdividing a rental property to substantially enhance the sales proceeds did not entail conversion to inventory | 295 |
Cristofaro v. Agence du revenu du Québec, 2019 QCCQ 6242
Paletta v. The Queen, 2019 TCC 205
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|---|---|---|
| Tax Topics - General Concepts - Sham | film marketing partnership loss denied on the basis that an alleged option was a sham | 415 |
| Tax Topics - Income Tax Regulations - Regulation 231 - Subsection 231(6) | expectation of repurchase option being exercised generated a prescribed benefit | 207 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expenses non-deductible because partnership expected to be repurchased before any income generated | 127 |
Rochefort v. Agence du revenu du Québec, 2019 QCCQ 2660 (Court of Quebec)
Les Développements Iberville Ltée v. Agence du Revenu du Québec, 2018 QCCA 1886 (Quebec Court of Appeal)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | abuse to use rollover provisions to avoid rather than defer tax | 633 |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | abuse of Quebec equivalents of ss. 85(1) and 97(2) to avoid (rather than defer) tax | 390 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | improvements to leased retail premises were not demonstrated to be made only at tenants’ requests | 106 |
| Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(6) | purpose of inter-provincial allocation rules is for 109% of income to be allocated and taxed | 510 |
| Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(1) | no policy of permitting differing Quebec and federal year ends | 185 |
Francoeur v. Agence du revenu du Québec, 2016 QCCQ 11906
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) | gain of builder eligible for exemption | 120 |
Staltari v. The Queen, 2015 DTC 1130 [at 818], 2015 TCC 123
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| Tax Topics - General Concepts - Evidence | uncorroborated testimony | 99 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | no business where no business organization | 167 |
| Tax Topics - Income Tax Act - Section 38 - Paragraph 38(a.2) | land donated in order to achieve tax benefit was still a gift to a qualified donee | 133 |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | exclusion of gains that are ordinary income | 149 |
Belcourt Properties Inc. v. The Queen, 2014 DTC 1182 [at 3678], 2014 TCC 208
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Zielinski v. The Queen, 2014 DTC 1023 [at 2635], 2013 TCC 384 (Informal Procedure)
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Bélanger v. The Queen, 2012 DTC 1235 [at 3651], 2012 TCC 93
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Peluso v. The Queen, 2012 DTC 1166 [at 3408], 2012 TCC 153
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9067-9051 Québec Inc., Vincent v. The Queen, 2012 DTC 1073 [at 2842], 2011 TCC 456
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | taxpayer unaware of factual basis for shareholder benefit | 200 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 152(4)(a)(i) is lesser threshold | 75 |
Von Realty Limited v. The Queen, 2011 DTC 1264 [at 1500], 2011 TCC 345
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Palardy v. The Queen, 2011 DTC 1188 [at 1050], 2011 TCC 108
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | income account treatment in "grey zone" | 133 |
| Tax Topics - Income Tax Act - Section 54 - Principal Residence | 151 |
Krauss v. The Queen, 2009 DTC 1394 [at 2155], 2009 TCC 597
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| Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) | family trust allocated unreasonable return on its nominal-cost units | 210 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 49 | |
| Tax Topics - Income Tax Act - Section 74.1 - Subsection 74.1(2) | 104 |
Dalron Construction Limited v. The Queen, 2008 DTC 4733, 2008 TCC 476
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Sivasubramaniam v. The Queen, 2008 DTC 3886, 2008 TCC 261 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(14) | 79 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(b) | 111 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | capital gains from resale not a permitted purpose | 63 |
Dubé v. The Queen, 2007 DTC 468, 2005 TCC 779 (Informal Procedure)
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Canada Safeway Limited v. The Queen, 2006 DTC 3144, 2006 TCC 345
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Twin Islands Estates Ltd v. The Queen, 2004 DTC 2515, 2004 TCC 141
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Willis v. The Queen, 2003 DTC 1081, 2003 TCC 575 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | gradual disposition program not indicative of change of use | 147 |
Fecteau v. The Queen, 2003 DTC 146 (TCC)
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Glassford v. The Queen, 2000 DTC 2531 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | land transaction not effective until reduced to writing | 69 |
Alexandroff v. The Queen, 95 DTC 767 (TCC)
Campeau v. MNR, 93 DTC 92 (TCC)
Marson v. Morton, [1986] BTC 377 (Ch. D.)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 43 |
Reeves Inc. v. MNR, 85 DTC 419 (TCC)
C.I.R. v. Reinhold (1953), 34 TC 389 (C.S. (1st. Div.))
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) | 167 |
Administrative Policy
30 March 2016 External T.I. 2016-0629701E5 F - bump-up 88(1)(d)
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| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) | land developer can bump the cost amount of land (for use by it as land inventory) which was held by a target as capital property when its control was acquired | 257 |
10 March 2015 External T.I. 2014-0552551E5 F - Vente du droit d'exploiter une sablière
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | sale of rights to extract sand generally not caught unless a profit à prendre | 128 |
| Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property | sale of rights to extract sand could be considered sale of qualified farm or fishing property | 168 |
20 January 2015 External T.I. 2014-0560961E5 - Treatment of creditor that has seized property
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25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | allocated capital gains retained their character unless re services performed by partner in course of separate business | 397 |
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(1) | distinction between return on partnership investment and services rendered by partner in the course of a separate business | 295 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | services rendered by limited partner to LP gave rise to ACB increase if no s. 9 income inclusion for fee income | 133 |
29 November 2012 External T.I. 012-0467841E5 -
11 February 2011 External T.I. 2010-0377171E5 F - Dépenses engagées à l'égard d'un immeuble locatif
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | renovation expenses to rental unit on capital account if lasting benefit for rental activities generated or an improvement over existing housing units is created | 177 |
2000 Ruling 2000-0028423 - partnership dissolution under 98(3)
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| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | 38 | |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | 82 | |
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) | 0% undivided interest | 38 |
Income Tax Technical News, No. 7, 21 February 1996 (cancelled)
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20 December 1995 External T.I. 9526825 - ENTRY FEE PAYMENTS & WITHHOLDING TAX
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|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | 98 |
4 March 1994 Internal T.I. 9321217 - SALE OF BURIAL PLOTS
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 69 |
8 January 1993 External T.I. 5-910367 -
8 January 1992 T.I. (Tax Window, No. 27, p. 19, ¶2359)
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 49 |
1992 A.P.F.F. Annual Conference, Q. 18 (January - February 1993 Access Letter, p. 57)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | conversion when commence to generate income | 35 |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(2) | 25 |
6 September 89 T.I. (February 1990 Access Letter, ¶1117)
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| Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(2) | 51 |
89 C.R. - Q.26
Robert Read, "Technical Matters," 1983 Annual CTF Conference Report, 783 at 785 under "Section 85 Rolls"
IT-459 "Adventure or Concern in the Nature of Trade"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 0 |
IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a) | 140 |
Articles
Sandler, "Character Roles: Property Transfers and Characterization Issues", 1996 Canadian Tax Journal, Vol. 44, No. 3, p. 605.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 0 |
Commentary