Cases
Labrador Offshore Shipping Co. Ltd. v. The Queen, 90 DTC 6096 (FCTD)
A diving support vessel which was used by Petro-Canada in its exploring and drilling operations in the seabed areas off the coast and outside of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property | use of leased property was by lessee rather than lessor | 123 |
See Also
Mersey Seafoods Ltd. v. MNR, 85 DTC 731, [1985] 2 CTC 2485 (TCC)
S.255 did not have the effect of deeming a factory trawler, which conducted its operations beyond the 12 nautical mile limit for Canada's...
Reference re Newfoundland Continental Shelf (1984), 5 DLR (4th) 385, [1984] 1 S.C.R. 86
Although "at international law ... the continental shelf off Newfoundland is outside the territory of the nation State of Canada...Canada has...
A.G. (Canada) v. A.G. (B.C.), [1984] 4 WWR 289 (SCC)
The submerged lands between Vancouver Island and the mainland belong to the province rather than Canada since those lands were part of the colony...
Administrative Policy
18 July 2013 External T.I. 2013-0493081E5 - Definition of "Outside Canada" - Water Boundaries
The correspondent asked when an individual engaged in offshore oil and gas exploration was "outside Canada" for the purpose of s. 122.3(1).
In...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 122.3 - Subsection 122.3(1) | 143 |
IT-494 "Hire of Ships and Aircraft from Non-Residents"
Canada includes the territorial sea of Canada as defined in the Territorial Seas and Fishing Zones Act, and the overlying airspace.
12 September 89 T.I. (February 1990 Access Letter, ΒΆ1124)
Neither section 255 of the Act, nor section 5 of the Income Tax Conventions Interpretation Act, are relevant to the interpretation of the "in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property | 28 |