Regulation 400 - Interpretation

Subsection 400(1)

Cases

MNR v. Spruce Falls Power and Power Co., 53 DTC 1214, [1953] CTC 325 (SCC)

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Subsection 400(2)

Cases

Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375

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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) reasonable filing position position cannot be a “misrepresentation” 508
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege not necessary to provide legal opinion to rely on having consulted legal counsel 215
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business Marconi test of "business" applied outside source-of-income context 136
Tax Topics - Statutory Interpretation - French and English Version "misrepresentation" informed by narrower French version 103

Sunbeam Corporation (Canada) Ltd. v. MNR, 62 DTC 1390, [1962] CTC 657 (SCC)

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MNR v. Panther Oil & Grease Manufacturing Co. of Canada Ltd., 61 DTC 1222 (Ex Ct)

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See Also

Martorelli v. The Queen, 2010 DTC 1156 [at 3313], 2010 TCC 216 (Informal Procedure)

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Toronto Blue Jays Baseball Club v. Minister of Finance (Ontario), 2005 DTC 5360 (Ont. CA)

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Ontario - Employer Health Tax Act - Subsection 1(2) - Permanent Establishment locker and coach's room used in away games were not a PE 106

Ivy Real Estate Corp. S.A. v. Deputy Minister of Revenue of Québec, [1989] 2 CTC 39 (Que. C.A.)

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Chicago Blower (Canada) Ltd. v. MNR, 66 DTC 471 (TAB)

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Enterprise Foundry (N.B.) Ltd. v. MNR, 64 DTC 660 (TAB)

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Words and Phrases
agency branch

Ronson Art Metal Works (Canada) Ltd. v. MNR, 56 DTC 440 (ITAB)

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Administrative Policy

12 June 2014 Ruling 133588r [30 continuous-days test for use of substantial equipment]

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - New Harmonized Value-Added Tax System Regulations, No. 2 - Subsection 2(2) 30 continuous-days test for use of substantial equipment 175

20 February 2014 External T.I. 2012-0460191E5 - Permanent establishment in a province

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9 May 2013 External T.I. 2012-0435401E5 F - Server as a PE in a province

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29 November 2011 November CTF Roundtable, 2011-0426561C6 - Public Warehouse: PIA

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20 July 2011 Internal T.I. 2011-0395341I7 -

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Income Tax Technical News, No. 2, December 30, 1994

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17 January 1994 T.I. 932892 (C.T.O. "Indian-Employment Income")

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13 January 1993 T.I. (Tax Window, No. 28, p. 13, ¶2381)

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4 September 1990 Memorandum (Tax Window, Prelim. No. 1, p. 22, ¶1011)

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81 C.R. - Q. 27

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I.T.-177R2 "Permanent establishment of a corporation in a province and of a foreign enterprise in Canada".

Articles

Tremblay, "Permanent Establishments in Canada", 1989 Conference Report, c. 38.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 5 0

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