Real Estate

Commentary

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Cases

Bodine v. Canada, 2011 DTC 5084 [at 5840], 2011 FCA 157

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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 49

Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39

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Roseland Farms Ltd. v. Canada, 99 DTC 5704 (FCTD), aff'd 2001 DTC 5392 (FCA), 2001 FCA 167

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 88

Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)

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Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103

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Leasehold Construction Corp. v. The Queen, 95 DTC 5470 (FCTD)

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Kaneff Properties Ltd. v. The Queen, 95 DTC 5345 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit gain from when commenced developing as commercial office tower was capital gain 146

Iula v. The Queen, 94 DTC 6614 (FCTD)

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Bellingham v. The Queen, 94 DTC 6564 (FCTD)

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Rivermede Developments Ltd. v. The Queen, 93 DTC 5365 (FCTD)

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Lee v. The Queen, 92 DTC 6067 (FCTD)

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Breakell v. The Queen, 91 DTC 5419 (FCTD)

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Witten v. The Queen, 91 DTC 5041 (FCTD)

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Snell Farms Ltd. v. The Queen, 90 DTC 6693 (FCTD)

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Homes Development Ltd. v. The Queen, 90 DTC 6654 (FCTD)

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King Edward Hotel (Calgary) Ltd. v. The Queen, 90 DTC 6468 (FCTD)

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W. Hanley & Co. Ltd. v. The Queen, 90 DTC 6354 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 148

Hertel v. The Queen, 90 DTC 6341 (FCTD)

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Grouchy v. The Queen, 90 DTC 6267 (FCTD)

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O&M Investments Ltd. v. The Queen, 90 DTC 6150 (FCTD)

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Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180 (FCTD)

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Crystal Glass Canada Ltd. v. The Queen, 89 DTC 5143 (FCA)

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Mintenko v. The Queen, 88 DTC 6537, [1989] 1 CTC 40 (FCTD)

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Sardo v. The Queen, 88 DTC 6464, [1988] 2 CTC 290 (FCTD)

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R. v. Landes, [1988] 1 CTC 124 (Queb. Ct. S.P.)

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Independent Gaz Service Inc. v. The Queen, 88 DTC 6230, [1988] 1 CTC 309 (FCTD)

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Johnstone v. The Queen, 88 DTC 6032, [1988] 1 CTC 48 (FCTD)

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Desrocher Development Corp. v. The Queen, 87 DTC 5363, [1987] 2 CTC 124 (FCTD)

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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)

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Happy Valley Farms Ltd. v. The Queen, 86 DTC 6421, [1986] 2 CTC 259 (FCTD)

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Biffis and Cappuccitti v. The Queen, 86 DTC 6403, [1986] 2 CTC 184 (FCTD)

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Algonquin Enterprises Ltd. v. The Queen, 86 DTC 6233, [1986] 1 CTC 493 (FCTD), aff'd 90 DTC 6377 (FCA)

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Future Investments Ltd. v. The Queen, 86 DTC 6224, [1986] 1 CTC 458 (FCTD)

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Marsted Holdings Ltd. v. The Queen, 86 DTC 6200, [1986] 1 CTC 436 (FCTD)

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Giannakos v. The Queen, 86 DTC 6145, [1986] 1 CTC 325 (FCTD)

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Regina Shoppers Mall Ltd. v. The Queen, 86 DTC 6091, [1986] 1 CTC 261 (FCTD), aff'd 89 DTC 5482 (FCA)

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Toolsie v. The Queen, 86 DTC 6117, [1986] 1 CTC 216 (FCTD)

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Jodare Ltd. v. The Queen, 86 DTC 6054, [1986] 1 CTC 250 (FCTD)

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Jacobson Holdings Ltd. v. The Queen, 85 DTC 5634, [1986] 1 CTC 87 (FCTD)

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Zen v. The Queen, 85 DTC 5531, [1985] 2 CTC 313 (FCTD)

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First Investors Corp. Ltd. v. The Queen, 85 DTC 5343, [1985] 2 CTC 96 (FCTD), aff'd 87 DTC 5175 (FCA)

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The Queen v. Bassani, 85 DTC 5232, [1985] 1 CTC 314 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 23

Woodbine Developments Ltd. v. The Queen, 84 DTC 6556, [1984] CTC 616 (FCTD)

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H. Fine and Sons Ltd. v. The Queen, 84 DTC 6520, [1984] CTC 500 (FCTD)

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W. Rudolph Construction Ltd. v. The Queen, 84 DTC 6454, [1984] CTC 457 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 37

Farmer Construction Ltd. v. The Queen, 84 DTC 6331, [1984] CTC 370 (FCTD)

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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)

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Niemi v. The Queen, 84 DTC 6189, [1984] CTC 181 (FCTD)

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Carsons Camps Ltd. v. The Queen, 84 DTC 6070, [1984] CTC 46 (FCTD)

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Marois v. The Queen, 83 DTC 5344, 84 DTC 6157 (FCTD)

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Sharon Mills Developments Ltd. v. The Queen, 83 DTC 5420, [1983] CTC 384 (FCTD)

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McDonald v. The Queen, 83 DTC 5264, [1983] CTC 211 (FCTD), aff'd 87 DTC 5276 (FCA)

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Belvedere Park Development Co. Ltd. v. The Queen, 83 DTC 5214, [1983] CTC 171 (FCTD)

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Van Anrep v. The Queen, 81 DTC 5278, [1981] CTC 358 (FCTD), aff'd 83 DTC 5100, [1983] CTC 84 (FCA)

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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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Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)

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Walton v. The Queen, 82 DTC 6220, [1982] CTC (FCTD)

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Colville-Reeves v. The Queen, 82 DTC 6005, [1981] CTC 512 (FCTD)

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South Shore Estates (Saltfleet) Ltd. v. The Queen, 81 DTC 5181, [1981] CTC 252 (FCTD)

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Kit-Win Holdings (1973) Ltd. v. The Queen, 81 DTC 5030, [1981] CTC 43 (FCTD)

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Leduc v. The Queen, 81 DTC 5017, [1981] CTC 21 (FCTD)

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The Queen v. Dumas, 80 D.T.C 6398, [1981] CTC (FCTD), rev'd 89 DTC 5004 (FCA)

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Jarvie Holdings Ltd. v. The Queen, 80 DTC 6395, [1980] CTC 525 (FCTD)

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Greenbranch Investments Ltd. v. The Queen, 80 DTC 6384, [1980] CTC 514 (FCTD)

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Marshall v. The Queen, 80 DTC 6357, [1980] CTC 475 (FCTD)

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Horvath v. The Queen, 80 DTC 6350, [1980] CTC 467 (FCTD)

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Robbie Holdings Ltd. v. The Queen, 80 DTC 6336, [1980] CTC 422 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 82

Glacier Realties Ltd. v. The Queen, 80 DTC 6243, [1980] CTC 308 (FCTD)

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Montford Lakes Estates Inc. v. The Queen, 79 DTC 5467, [1980] CTC 27 (FCTD)

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Hummel Corp. of Quebec Ltd. v. The Queen, 79 DTC 5426, [1979] CTC 483 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 48

Gamble v. The Queen, 79 DTC 5397, [1979] CTC 463 (FCTD)

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Caponecchia v. The Queen, 79 DTC 5364, [1979] CTC 445 (FCTD)

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Kensington Land Developments Ltd. v. The Queen, 79 DTC 5283, [1979] CTC 367 (FCA)

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Demeter Equity Ltd. v. The Queen, 79 DTC 5230, [1979] CTC 311 (FCTD)

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Riznek Construction Ltd. v. The Queen, 79 DTC 5131, [1979] CTC 197 (FCTD)

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Edmund Peachey Ltd. v. The Queen, 79 DTC 5064, [1979] CTC 51 (FCA)

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Locations of other summaries Wordcount
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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Cohen v. The Queen, 78 DTC 6099, [1978] CTC 63 (FCTD), aff'd 80 DTC 6250, [1980] CTC 318 (FCA)

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The Queen v. Randall Park Development Ltd., 78 DTC 6545, [1978] CTC 826 (FCTD)

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Choice Realty Corp. v. The Queen, 78 DTC 6415, [1978] CTC 613 (FCTD)

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Locations of other summaries Wordcount
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 137
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)

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Birmount Holdings Ltd. v. The Queen, 78 DTC 6254, [1978] CTC 358 (FCA)

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The Queen v. Borinsky, 77 DTC 5389, [1977] CTC 570 (FCTD)

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The Queen v. Froese, 77 DTC 5364, [1977] CTC 526 (FCTD)

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Reicher v. The Queen, 76 DTC 6001, [1976] CTC 659 (FCA)

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Fredericton Housing Ltd. v. The Queen, 75 DTC 5367, [1975] CTC 537 (FCA)

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McDonald v. The Queen, 74 DTC 6644, [1974] CTC 836 (FCA)

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Sikler v. The Queen, 73 DTC 5553, [1973] CTC 736 (FCTD)

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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
investing

Balstone 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)

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Hazeldean Farm v. MNR, 66 DTC 5397, [1967] 1 Ex CR 245

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Racine v. MNR, 65 DTC 5098 (Ex Ct)

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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 133

Regal Heights Ltd. v. Minister of National Revenue, 60 DTC 1270, [1960] CTC 384, [1960] S.C.R. 902

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McIntosh v. Minister of National Revenue, 58 DTC 1021, [1958] CTC 18, [1958] S.C.R. 119

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See Also

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 91
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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence uncorroborated testimony 80
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business no business where no business organization 155
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 119
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) exclusion of gains that are ordinary income 139

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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Locations of other summaries Wordcount
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 192
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 152(4)(a)(i) is lesser threshold 71

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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Krauss v. The Queen, 2009 DTC 1394 [at 2155], 2009 TCC 597

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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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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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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) gradual disposition program not indicative of change of use 145

Fecteau v. The Queen, 2003 DTC 146 (TCC)

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Glassford v. The Queen, 2000 DTC 2531 (TCC)

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Tax Topics - General Concepts - Effective Date 65

Alexandroff v. The Queen, 95 DTC 767 (TCC)

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Campeau v. MNR, 93 DTC 92 (TCC)

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Marson v. Morton, [1986] BTC 377 (Ch. D.)

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Reeves Inc. v. MNR, 85 DTC 419 (TCC)

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C.I.R. v. Reinhold (1953), 34 TC 389 (C.S. (1st. Div.))

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Administrative Policy

30 March 2016 External T.I. 2016-0629701E5 F - bump-up 88(1)(d)

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Locations of other summaries Wordcount
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 247

10 March 2015 External T.I. 2014-0552551E5 F - Vente du droit d'exploiter une sablière

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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 122
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 154

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 381
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 279
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 127

29 November 2012 External T.I. 012-0467841E5 -

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2000 Ruling 2000-002842 -

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Income Tax Technical News, No. 7, 21 February 1996 (cancelled)

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20 December 1995 T.I. 952682 (C.T.O. "Entry Fee Payments and Withholding Tax")

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4 March 1994 Memorandum 932121 (C.T.O. "Sale of Burial Plots")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit 67

8 January 1993 External T.I. 5-910367 -

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8 January 1992 T.I. (Tax Window, No. 27, p. 19, ¶2359)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit 47

1992 A.P.F.F. Annual Conference, Q. 18 (January - February 1993 Access Letter, p. 57)

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6 September 89 T.I. (February 1990 Access Letter, ¶1117)

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89 C.R. - Q.26

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Robert Read, "Technical Matters," 1983 Annual CTF Conference Report, 783 at 785 under "Section 85 Rolls"

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IT-459 "Adventure or Concern in the Nature of Trade"

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".

Articles

Sandler, "Character Roles: Property Transfers and Characterization Issues", 1996 Canadian Tax Journal, Vol. 44, No. 3, p. 605.

Warnock, "Income or Capital Gains on Dispositions of Property", 1990 Conference Report, c. 48.