Words and Phrases - "principally"
26 July 2010 External T.I. 2010-0364721E5 F - Revenus de bien et d'entreprise
After concluding that “the operator of a bed and breakfast, who has a personal residence in which bed and breakfast rooms are rented out on a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(12) | bed and breakfast operation was business rather than property source (and thus subject to s. 18(12) limitation) since more than normal essential services provided | 166 |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | reduction of personal expenses is not the pursuit of profit | 97 |
Gestions Calce Ltée v. Agence du revenu du Québec, 2019 QCCQ 7377
One of the exceptions from the rule that a rental property cannot qualify as a “former business property” for purposes of the replacement...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property | property was used more than 50% in active business of related lessee given actual use (in excess of written lease terms) | 337 |
S3-F3-C1 - Replacement Property
Meaning of "principally"
1.30 Where property is used in part to earn gross revenue that is rental income and in part to earn income from a...
11 February 2014 External T.I. 2014-0517611E5 F - Actions d'une société agricole familiale
In year 1 Father purchased Opco, in year 5 he transferred his shares equally to Child 1 who actively explanted the farming business of Opco along...
17 February 1992 T.I. 920014 (March 1993 Access Letter p. 86, ¶C248-127; Tax Window, No. 16, p. 18, ¶1753)
If more than 50% of an asset is used in an active business, the asset will be considered to be used principally in an active business.
12 January 1993 T.I. 923151 (November 1993 Access Letter, p. 503, ¶C109-154)
The use of the word "principally" requires that the property as a whole be considered rather than a percentage or a portion of the property....