Words and Phrases - "principal purpose"

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

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 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231

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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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