Words and Phrases - "in the course of"

a
85
b
44
c
75
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
88
t
46
u
15
v
9
w
22
y
2

President's Choice Bank v. Canada (the King), 2024 FCA 135

Summary Under
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(5)
loyalty point redemption payments made in the course of a financial business could generate ITCs if also in the course of a commercial activity

A corporation (“PC Bank”) in the Loblaw group, whose business was to grant credit through the operation of a MasterCard program, obtained the...

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Words and Phrases
in the course of
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) s. 169(1) requires apportionment of an acquisition of a property or service between commercial and exempt activity 72
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity commercial activity of corporation can be at a loss 144

25 April 2002 Internal T.I. 2002-0131937 F - FRAIS D'EMPRUNT-EVALUATION ARPENTAGE

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(ii)
cost of appraisal fee required by mortgage lender was deductible

A taxpayer who used a second-mortgage loan on the individual’s residence to make interest and dividend-generating investments, was required by...

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Words and Phrases
in the course of

Glencore Canada Corporation v. Canada, 2024 FCA 3

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)
break fee was includible under s. 12(1)(x)

An integrated nickel-mining public company (“Falconbridge”), entered into merger agreements with a more junior public company (“Diamond...

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Words and Phrases
inducement in the course of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments break fee was a capital receipt 188
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property break fee was not consideration for the disposition of a merger right as there was no such “right” 215
Tax Topics - Income Tax Act - Section 54 - Capital Property break fee was not proceeds of disposition of a capital property 176

7 April 2022 CBA Roundtable, Q.14

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2 - Paragraph 2(a)
zero-rating under s. 2(a) for supplies to an airline relates to connected property or services, but not to the aircraft itself

Does Sched. VI, Pt. V, s. 2 zero-rate all property that is purchased or leased by a non-resident airline whose sole activity is to carry on the...

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Words and Phrases
in the course of

28 April 2004 Internal T.I. 2004-0066991I7 F - Paiement incitatif

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)
incentive payments received from broker to purchase an exempt life insurance policy were received “in the course of earning income from … property” (the policy)

As an incentive for the sale of exempt life insurance policies (having a savings and investment component) a life insurance brokers would pay to...

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Words and Phrases
in the course of in the course of earning income from … property
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property property “includes practically any type of economic interest” 142
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose per MacIntyre, life insurance premiums are not deductible from business income 192

MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e)

In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus...

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Words and Phrases
commission in the course of

Higgs v. Olivier (1952), 33 TC 136 (C.A.)

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)

Before going on to find that a lump sum received by an actor in consideration for his covenant not to exercise his vocation for a period of 18...

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Words and Phrases
in the course of

Blok-Andersen v. MNR, 72 DTC 6309, [1972] CTC 338 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 112 - Subsection 112(2.1)

In the course of considering a submission that s. 85B(1)(B) of the pre-1972 Act (now s. 12(1)(b)) did not apply to an adventure in the nature of...

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Words and Phrases
in the course of