Section 79
Subsection 79(7)
Cases
Stonehouse Group Inc. v. Ontario (Finance), 2021 ONCA 10
As a result of being reassessed in 2013 to deny the carryback of a loss, the taxpayer was required to pay the reassessed taxes for 2013,...
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Tax Topics - Statutory Interpretation - Absurdities | “the principle that governments have the right to legislate illogically” was “not … persuasive” | 205 |
Subsection 11(5.1)
Administrative Policy
Bulletin 3004 "Management Fees, Rent, Royalties and Similar Amounts Paid or Payable to Non-residents" January 2002
2. Subsection 11(5.1) describes the payments which must be added to income. These payments fall into the following categories:
1. Management or...
Section 53
Cases
Harold Gross Machinery Inc. v. Minister of Finance (1998), 162 DLR (4th) 509 (Ont CA)
The taxpayer, which was required to provide a guarantee of payment for its purchases of machinery worldwide, did so by having its bank arrange...
Subsection 53(1)
Cases
Upper Lake Shipping Ltd. v. Minister of Finance, 98 DTC 6264, [1998] 3 CTC 281 (Ont CA)
Given that generally accepted accounting principles require that a government grant relating to a capital asset be included in retained earnings...
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Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) | 57 |
Subsection 53(1)
Section 57.9
Subsection 57.9(1)
Administrative Policy
Ontario corporate minimum tax 25 April 2020
Canadian GAAP or IFRS
Corporate minimum tax is based on the adjusted net income of a corporation. The adjusted net income is a corporation's net...
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Tax Topics - Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 60 - Subsecion 60(1) | 236 |
Section 61
Cases
QEW 427 Dodge Chrysler (1991) Inc. v. Minister of Revenue (2000), 49 OR (3d) 776 (S CT J), aff'd (2002), 50 OR (3d) 460 (S Ct J, Div Ct), 2002 DTC 7228
Chrysler Canada would sell cars to the taxpayer (an automobile dealer) under conditional sales contracts, and sell the conditional sales contracts...
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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 133 |
Regulations
Regulation 302
Subsection 302(7)
Cases
W.E. Roth Construction Ltd. v. Minister of Finance (2001), 141 OAC 366 (CA)
The taxpayer managed its Ontario properties through four Ontario employees, whereas its Alberta properties were managed by three corporations...
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Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(7) | 104 |