Words and Phrases - "ordinary course of the business"

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19 October 2023 Internal T.I. 2020-0856851I7 - Ordinary Course of Business

MRPS acquired by a Canadian insurance company subsidiary in order for the Luxco to loan-finance US operations were not acquired in the ordinary course

In 2010, a Canadian corporation, which was a specified financial institution by virtue of being controlled by its parent, a Canadian insurance...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(2.1) MRPS used to finance US opco or opco acquisition were not acquired in the ordinary course of the business 360

3 May 2006 Internal T.I. 2005-0133341I7 F - Cours normal des activités de l'entreprise

s. 112(1) applies to dividends received through partnership/whether venture capital firm received such dividends in ordinary course turned on similarity of this with its other investments

As part of a reorganization relating to the sale of a share investment in Bco by Aco (a specified financial institution), a partnership of which...

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576315 Alberta Ltd. v. The Queen, 2001 DTC 776 (TCC)

16 loans made as ordinary part of leasing and lending business

The taxpayer ("241467"), which previously had engaged exclusively in a leasing business, was found to be engaged in a financing business that...

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Bastion Management Ltd. v. The Queen, 95 DTC 5238, [1995] 2 CTC 252 (FCA)

physical trades not in ordinary course of futures trader's business

The taxpayer, which was a trader in commodity futures, purchased 15,000 ounces of gold and 500,000 ounces of silver shortly before its year-end...

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Purpose 86

Société d’Investissement Desjardins v. Minister of National Revenue, 91 DTC 393, [1991] 1 CTC 2214 (TCC)

The taxpayer, which was a venture capital corporation, was found not to have received a deemed dividend on a term preferred share in the ordinary...

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