Words and Phrases - "ordinary course of the business"
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...
| 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...
Words and Phrases
ordinary course of the business576315 Alberta Ltd. v. The Queen, 2001 DTC 776 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii)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...
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...
Words and Phrases
ordinary course of the business| 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...
Words and Phrases
ordinary course of the business