Words and Phrases - "in connection with"

a
85
b
44
c
76
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
89
t
46
u
15
v
9
w
22
y
2

BlackBerry Limited v. The King, 2024 TCC 123

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b)
s. 95(3)(b) exclusion applied where inbound R&D services from US subsidiaries were inextricably linked with product sales

The taxpayer (“BlackBerry”), which in its 2010 taxation year generated $8 billion in sales of smartphones to BlackBerry US, which on-sold...

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Words and Phrases
in connection with
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(b) - Subparagraph 95(2)(b)(i) s. 95(2)(b)(i) was inapplicable where no net inbound services were provided 221
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(d) s. 95(3)(d) exclusion applied where inbound R&D services from US subsidiaries were inextricably linked with offshore manufacturing 224
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4) US tax credit for R&D work of US affiliates was allocated to the US consolidated group (earning business income) rather than to those particular affiliates (allegedly earning FAPI) 170

19 October 2004 Internal T.I. 2004-0094971I7 F - Programme de formation admissible

Summary Under
Tax Topics - Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program
“period” referred to the times at which the individual was receiving income from employment

The Directorate indicated that the word “period” in the pre-2004 version of para. (b) of the definition of “qualifying educational...

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Words and Phrases
period in connection with

ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA

Summary Under
Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a)
services acquired long after the cessation of commercial activity may give rise to input tax credits

The appellant (“Look”), which had been carrying on a telecommunications business, sold its licences (including its “Spectrum” licence) ,...

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Words and Phrases
in connection with

13 January 2015 Internal T.I. 2013-0497361I7 F - Services performed by a foreign affiliate

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b)
prototype testing services not directly related to sales of improved product

A foreign affiliate ("FA1") of a Canadian manufacturer (the "Taxpayer") provides testing services to the Taxpayer on products (namely, prototypes)...

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Words and Phrases
in connection with
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(d) prototype testing services not manufacturing 123

Reiner v. The Queen, 2005 DTC 308, 2005 TCC 115 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program

The taxpayer, who was a full-time teacher, also was pursuing a course of studies at a U.S. university leading to a Master of Arts in Curriculum...

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Words and Phrases
in connection with