Words and Phrases - "principal purpose"

a
86
b
44
c
77
d
51
e
38
f
31
g
18
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
90
t
46
u
15
v
9
w
23
y
2

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F - entreprise exploitée activement – revenu de location

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business
principal purpose means main or chief objective

In the course of a general discussion as to whether a Canadian-controlled private corporation with rental properties carried on an active...

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Words and Phrases
principal purpose
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Active Business Carried On by a Corporation question of fact whether a CCPC with too many employees to have a specified investment business carries on a business 218

0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business
storage charges were property income, cf. hotel revenue

The taxpayer, which had two employees including its shareholder, carried on a storage unit rental business.

Before referring to the "principal...

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Words and Phrases
principal purpose income from property
Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus Minister's pleading of assumptions of law does not relieve taxpayer from entering a case 106