Cases
See Also
Addy v Commissioner of Taxation, [2021] HCA 34
Commissioner of Taxation v Addy, [2020] FCAFC 135, rev'd [2021] HCA 34
Addy v Commissioner of Taxation, [2019] FCA 1768, reinstated by [2021] HCA 34 after being rev'd by [2020] FCAFC 135
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 20-month non-“itinerant” stay under working visa based at a Sydney Australia home was residence | 209 |
Kenny v. The Queen, 2018 TCC 2 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.94 | foreign government assistance scuppered the “substantially all” test in s. 118.94 | 302 |
CIT v. Herbalife International India Pvt. Ltd, ITA 7/2007, 13 May 2016 (Delhi High Court)
Hillis v. Canada (Attorney General), 2015 FC 1082
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | regard to object rather than political statements | 55 |
| Tax Topics - Treaties - Income Tax Conventions - Article 26A | Art. 26 of US Convention did not prohibit FATCA information exchanges | 174 |
| Tax Topics - Treaties - Income Tax Conventions - Article 27 | FATCA information exchanged automatically irrespective of any substantive U.S. tax liability was "relevant" to U.S. tax administration | 387 |
Administrative Policy
25 May 2017 External T.I. 2017-0685651E5 - Non-capital losses of LLC
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17 May 2010 External T.I. 2009-0346011E5 F - Immeuble - Convention Canada - Portugal
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (a) | Portuguese home of Canadian resident could qualify for the principal residence exemption | 57 |