reasonable

Pinnacle International Realty Group II Inc. v. The King, 2023 TCC 161 -- summary under Subsection 103(1)

Full Title
Pinnacle International Realty Group II Inc. v. The King, 2023 TCC 161
Summary Under
Tax Topics - Income Tax Act - Section 103 - Subsection 103(1)
partnership profit reallocated under s. 103(1) based on relative contribution

The taxpayer and another wholly-owned subsidiary (“Taylor”) of the same corporation (“PIRG”) were the 5% and 95% partners, respectively,...

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Words and Phrases
reasonable

Connolly v. Canada (National Revenue), 2019 FCA 161 -- summary under Subsection 204.1(4)

Full Title
Connolly v. Canada (National Revenue), 2019 FCA 161
Summary Under
Tax Topics - Income Tax Act - Section 204.1 - Subsection 204.1(4)
CRA internal guidelines on waiving the RRSP over-contribution tax were inherently unreasonable

The taxpayer did not file income tax returns for the 1988 to 2003 taxation years on the basis that as he owed no tax, this was unnecessary. Thus,...

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reasonable

Sun Life Assurance Company of Canada v. The Queen, 2015 TCC 37 -- summary under Subsection 141.01(5)

Full Title
Sun Life Assurance Company of Canada v. The Queen, 2015 TCC 37
Summary Under
Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(5)
holding of vacant office space by a GST-exempt business for potential future taxable rentals qualified for ITC purposes as commercial activity/ first order intended supply of vacant space was for rentals

The appellant ("Sun Life"), whose principal business was the sale of financial products, subleased space in its various office buildings to...

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reasonable
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