Subsection 1204(1)
Cases
3850625 Canada Inc. v. The Queen, 2010 DTC 1089 [at 2976], 2010 TCC 104, aff'd 2011 DTC 5062 [at 5714], 2011 FCA 117
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The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065 (FCA)
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Gulf Canada Resources Ltd. v. The Queen, 95 DTC 5189 (FCTD), partially rev'd 96 DTC 6065 (FCA).
Echo Bay Mines Ltd. v. The Queen, 92 DTC 6437 (FCTD)
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Words and Phrases
hedgeInternational Nickel Co. of Canada Ltd. v. MNR, 71 DTC 5332 (FCTD)
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See Also
ATCO Electric Ltd. v. The Queen, 2007 DTC 974, 2007 TCC 243
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Administrative Policy
29 November 2012 Internal T.I. 2012-0462361I7 - Meaning of "Prime Metal Stage or its Equivalent"
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 65 | 131 |
26 January 1996 T.I. 960301 (C.T.O. "Resource Profits, Diamonds, Prime Metal Stage")
28 July 1995 Internal T.I. 7-951496 -
24 December 1992 Memorandum (Tax Window, No. 27, p. 14, ¶2337)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 59 |
92 C.R. - Q.17
89 C.R. - Q.22
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 42 |
89 C.P.T.J. - Q21
89 C.P.T.J. - Q22
Paragraph 1204(1)(b)
See Also
Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715
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Words and Phrases
consideration| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | shifting CRA position could not be relied upon except to evidence ambiguity | 73 |
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | presumption against tautology | 114 |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | residual presumption in favour of the taxpayer | 125 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges | “hedging “ includes cash settled derivatives including options | 415 |
| Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation | addition of regulation did not significantly expand scope of tax | 223 |
Subparagraph 1204(1)(b)(ii)
See Also
Barrick Gold Corporation v. The Queen, 2017 TCC 18
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | character of hedging gain was a legal question not affected by accounting | 104 |
Paragraph 1204(1)(f)
Administrative Policy
28 July 1995 Internal T.I. 7-951496 -
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 38 | |
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 26 |
Subsection 1204(1.1)
Administrative Policy
20 January 2010 Internal T.I. 2009-0348571I7 - Interest Rate Swaps and Resource Profits
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | 157 |
Articles
Richardson, "Cominco, Westar, and the Legacy of a Gulf", 1993 Canadian Tax Journal, Vol. 41, No. 4, p. 672.
Subsection 1204(3)
Cases
The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065 (FCA)
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Paragraph 1204(3)(a)
See Also
Exxonmobil Canada Ltd. v. The Queen, 2019 TCC 108
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Words and Phrases
derived| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | initial well placed in order to validate improved reservoir analysis was not SR&ED | 308 |