Cases
Kruger Incorporated v. Canada, 2016 FCA 186
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | derivatives not held for resale are not inventory | 155 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | Minister implicitly directed to reduce taxpayer's income below that originally filed | 98 |
Urbandale Realty Corp. Ltd. v. The Queen, 2000 DTC 6118 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 56 |
Canada v. Canada Safeway Limited, 98 DTC 6060 (FCA)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | sales tax refund not reimbursement | 96 |
Toronto College Park Ltd. v. Canada, [1998] 1 S.C.R. 183
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Ikea Ltd. v. Canada, 98 DTC 6092, [1998] 1 S.C.R. 196
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | tenant inducement payment was received in course of retail store operations | 128 |
| Tax Topics - Statutory Interpretation - Symmetry | 24 |
Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147
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| Tax Topics - General Concepts - Onus | 95 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 55 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 151 |
The Queen v. Johnson & Johnson Inc., 94 DTC 6125 (FCA)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 52 | |
| Tax Topics - Statutory Interpretation - Certainty | 86 |
Friedberg v. Canada, 93 DTC 5507, [1993] 4 S.C.R. 285
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West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023 (FCA)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 188 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 109 |
R. v. Fogazzi, 92 DTC 6421 (Ont. C.J. (G.D.)), rev'd 93 DTC 5183 (Ont. CA)
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| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 89 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 75 | |
| Tax Topics - Income Tax Act - Section 3 | 103 |
Maritime Telegraph and Telephone Co. Ltd. v. The Queen, 91 DTC 5038 (FCTD), aff'd 92 DTC 6191 (FCA)
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 29 |
Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 77 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve for revenues collected at excess rate | 96 |
Dixie Lee (Maritimes) Ltd. v. The Queen, 88 DTC 6108 (FCTD), aff'd 91 DTC 5518 (FCA)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | substantial performance of services in 1st year | 121 |
Burrard Yarrows Corp. v. The Queen, 86 DTC 6459, [1986] 2 CTC 313 (FCTD), aff'd sub nomine Versatile Pacific Shipyards Inc. v. The Queen, 88 DTC 6352 (FCA)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 62 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve if s. 9 inclusion | 23 |
Zoel Chicoine Inc. v. The Queen, 86 DTC 6251, [1985] 2 CTC 320 (FCTD), aff'd 87 DTC 5409, [1987] 2 CTC 240 (FCA)
Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(m) | 85 |
The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)
Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122 (FCA)
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Commonwealth Construction Co. Ltd. v. The Queen, 82 DTC 6152, [1982] CTC 167 (FCTD), aff'd 84 DTC 6420, [1984] CTC 338 (FCA)
Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)
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| Tax Topics - General Concepts - Estoppel | 46 | |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 58 |
Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Disposition of Property | 57 |
Oxford Shopping Centres Ltd. v. The Queen, 79 DTC 5458, [1980] CTC 7, aff'd 81 DTC 5065, [1981] CTC 128 (FCA)
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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 | perimeter road construction for promotion | 136 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Marketing Expenditures | 136 |
Maple Leaf Mills Ltd. v. Minister of National Revenue, 76 DTC 6182, [1976] CTC 324, [1977] 1 S.C.R. 558
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Harlequin Enterprises Ltd. v. The Queen, 74 DTC 6634, [1974] CTC 838 (FCTD), aff'd 77 DTC 5164, [1977] CTC 208 (FCA)
Françon Ltée v. MNR, 73 DTC 5514, [1973] CTC 708 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense | 86 |
Minister of National Revenue v. Benaby Realties Limited, 67 DTC 5275, [1967] CTC 418, [1968] S.C.R. 12
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 146 |
Minister of National Revenue v. Atlantic Engine Rebuilders Ltd., 67 DTC 5155, [1967] CTC 230, [1967] S.C.R. 477
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 130 |
Minister of National Revenue v. Lechter, 66 DTC 5300, [1966] CTC 434, [1966] S.C.R. 655
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| Tax Topics - General Concepts - Effective Date | 90 |
Canadian General Electric Company v. The Minister of National Revenue, 61 DTC 1300, [1961] CTC 512, [1962] S.C.R. 3
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MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 73 |
Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)
Minister of National Revenue v. Imperial Oil Co., 60 DTC 1219, [1960] CTC 275, [1960] S.C.R. 735
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MNR v. Publishers Guild of Canada Ltd., 57 DTC 1017, [1957] CTC 1 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 93 |
Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433
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| Tax Topics - General Concepts - Evidence | 30 |
Ken Steeves Sales Ltd. v. MNR, 55 DTC 1044 (Ex Ct)
Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82
Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 106 |
See Also
Mazo v. The Queen, 2016 TCC 232 (Informal Procedure)
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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 3 - Business Source/Reasonable Expectation of Profit | pyramid scheme a source of business income | 86 |
GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | amount subject to potential repayment obligation was not received | 240 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) | amounts replaced reduced lease income rather than contributing to leased vehicles' cost | 217 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | capital tax accrued from day to day | 206 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income | 248 |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | surcharges received by lessor at lease termination for excess use were income | 242 |
Kruger Incorporated v. The Queen, 2015 DTC 1127 [at 788], 2015 TCC 119, rev'd 2016 FCA 186
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| 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 4 - Subsection 4(1) - Paragraph 4(1)(a) | paper manufacturer's large-scale options-trading operation was a separate business | 156 |
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 3 | 151 |
Reilly v. The Queen, 2010 DTC 1223 [at 3623], 2010 TCC 326
Langille v. The Queen, 2009 DTC 1431, 2009 TCC 398
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 87 |
Destacamento v. The Queen, 2009 DTC 806, 2009 TCC 242 (Informal Procedure)
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2187878 Nova Scotia Limited v. The Queen, 2007 DTC 761, 2007 TCC 249
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Ferro v. The Queen, 2003 DTC 491 (TCC)
Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 47 |
Iron Ore Co. of Canada v. The Queen, 2000 DTC 1725 (TCC)
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Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 75 |
R. & J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)
Fleur de Lys Warehousing Ltd. v. MNR, 91 DTC 1343 (TCC)
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| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 49 |
Yesac Creative Foods Inc. v. MNR, 91 DTC 413 (TCC)
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | 81 |
Recordwide Distributors, Inc. v. C.I.R., 82-2 U.S.TC 84:713 (C.A. 8)
Willingale v. International Commercial Bank Ltd. (1978), 52 TC 242 (HL)
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 88 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 36 |
Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)
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| Tax Topics - General Concepts - Fair Market Value - Other | 56 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | benefit in year of note issuance/tenant improvement benefit based on PV of reversion boost | 305 |
Burley Tobacco Growers Cooperative Association, Inc. v. U.S., 68-2 U.S.TC 87:579 (D.C. Ky.)
British South Africa Co. v. Varty, [1966] A.C. 381 (HL)
Automobile Club of N.Y., Inc. v. CIR, 62-2 U.S.TC 85:342 (C.A. 2)
Elson v. Prices Taylors, Ltd. (1962), 40 TC 671 (Ch. D.)
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Anderson Logging Co. v. The Queen, 52 DTC 1215 (PC)
Jay's - The Jewellers, Ltd. v. C.I.R. (1947), 29 TC 274 (K.B.D.)
Cowen's Ideal Trading Stamp Co. (Glasgow) Ltd. v. C.I.R. (1934), 19 TC 154 (C.S. (1st D.))
Administrative Policy
21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges | hedges re dividend or interest obligations of parent on income account | 194 |
9 October 2015 APFF Roundtable Q. 9, 2015-0595661C6 F - Question 9 - Table Ronde APFF 2015
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | s. 20(1)(m) reserve may be claimable for an amount included under s. 9 rather than 12(1)(a) | 139 |
23 December 2014 External T.I. 2013-0487791E5 F - Période d'amortissement du revenu d'emphytéose
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | sum received on granting an emphyteusis is proceeds of disposition | 179 |
6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | irrevocable royalty prepayment under s. 12(1)(a) or 9 | 128 |
10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Boni suite à la signature d'un contrat d'appro
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11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder | 109 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder | 164 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder | 169 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 | 218 |
| Tax Topics - General Concepts - Fair Market Value - Options | stock options with no in-the-money value could have nil FMV | 128 |
| Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) | s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares | 157 |
2 April 2013 External T.I. 2013-0475571E5 - Life insurance
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 124 | |
| Tax Topics - Income Tax Act - Section 32 - Subsection 32(1) - Paragraph 32(1)(a) | 124 |
22 November 2011 External T.I. 2011-0404021E5 F - Revenu des entrepreneurs
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29 August 2011 Internal T.I. 2009-0336671I7 - Derivative
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | interest rate swap not a debt obligation | 91 |
20 March 2012 External T.I. 2011-0424461E5 F - Déduction d'une rétribution à un agent immobilier
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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 | lease-up commissions were current expenses | 108 |
Income Tax Technical News-42, 31 May 2010
19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | derivative that effectively locked in effective interest rate on proposed bond issuance on income account | 111 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | hedging expense to lock in interest rate | 103 |
26 May 2008 Internal T.I. 2008-0272771I7 - Straight-line Amortization or Averaging of Rent
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24 March 2003 External T.I. 2003-018412 -
1999 Ruling 990354
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| Tax Topics - Income Tax Act - Section 18.1 - Subsection 18.1(15) | 144 |
25 March 1999 Memorandum 9828577
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 47 |
3 May 2000 T.I. 1999 - 001391
23 November 1999 T.I. 982440
22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 128 | |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | financial liabilities not to be marked to market | 128 |
11 April 1990 T.I. AC58705 File 5-8705
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 122 |
Income Tax Technical News, No. 16, 8 March 1999: Comments on Canderel, College Park and Ikea cases.
Income Tax Technical News, No. 14, "Reporting of Derivative Income by Mutual Funds"
Income Tax Technical News, No. 8, 30 September 1996, "Proceeds of Sale of a Condominium - First Closing Date or Second Closing Date".
23 July 1996 T.I. 961591 (C.T.O. "Timing of Revenue Recognition")
5 December 1995 T.I. 951614 (C.T.O. "Lease Inducements")
29 March 1995 Memorandum 941955 (C.T.O. "Federal Sales Tax Refund")
Income Tax Technical News, No. 1, 22 July 1994
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii) | taxable co-owner permitted | 31 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 65 |
19 July 1994 Memorandum (C.T.O. "Mutual Fund Limited Partnerships")
31 October, 1994 T.I. 942162 (CTO "Income Recognition")
25 August 1994 Memorandum 941952 (C.T.O. "Short-term Contracts")
21 June 1994 External T.I. 5-941406 -
3 February 1994 External T.I. 5-932925 -
Halifax Round Table, February 1994, Q. 23
1994 A.P.F.F. Round Table, Q. 25
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 44 |
Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.")
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9 January 1993 Memorandum (Tax Window, No. 30, p. 9, ¶2487)
13 May 1992 Internal T.I. 7-921151 -
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 19 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | gold loans of producers | 17 |
91 C.R. - Q.41
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Effective Date | 49 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 35 |
16 July 1991 T.I. (Tax Window, No. 6, p. 14, ¶1350)
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| Tax Topics - Income Tax Act - Section 216 - Subsection 216(1) | 47 |
14 May 1991 T.I. (Tax Window, No. 3, p. 13, ¶1238)
15 January 1990 Memorandum (June 1990 Access Letter, ¶1287)
15 January 1990 Memorandum (June 1990 Access Letter, ¶1251)
89 C.R. - Q.30
89 C.R. - Q.22
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| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 45 |
87 C.R. - Q.25
85 C.R. - Q.31
IT-479R, para. 28-32
Articles
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36
Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 5 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 5 |
Harris, "Developments in Asset-backed Financing: Tax Considerations", Business Vehicles, Vol. III, No. 3, 1997, p. 136
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) | 14 | |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 34 |
Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) | 11 | |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b) | 15 |