Words and Phrases - "primarily"

a
87
b
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51
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74
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2
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32
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56
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25
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GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule IX - Part I - Section 4

Determination of ordinary location by agreement

17. The place of supply rules for intangible personal property that relate to tangible personal...

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Words and Phrases
primarily

Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 - Paragraph 1(a) - Subparagraph 1(a)(ii)
CIBC’s interchange fees from a non-resident credit-card processor were not zero-rated as relating to the loans effectively made to its Cdn. cardholders

In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...

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Words and Phrases
relates to lending debt primarily

24 April 2002 External T.I. 2001-0095755 F - TÉLÉTRAVAIL

Summary Under
Tax Topics - Income Tax Act - Section 8 - Subsection 8(13)
telework arrangement, even if voluntary, and some time spent in the employer office, can satisfy s. 8(13) requirements/ time spent on the road does not satisfy the “primarily” requirement

The Employe is now permitting employees to choose to perform their duties from home (“telework”) so that employees can perform the tasks...

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Words and Phrases
primarily

16 July 2021 Internal T.I. 2020-0872521I7 - CERS - Qualifying property for rental income

Summary Under
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Rent Expense - Variable A - Paragraph (b)
significant additional services transform rental income into income from services

Would the owner of a qualifying property that operates a hotel, or other similar business such as a motel or a bed and breakfast, be considered to...

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Words and Phrases
rent income primarily

20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole

Summary Under
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c)
test is of intention on acquisition to use over 50%, during months of likely use during the equipment’s lifetime, on farm in the region

Two taxpayers, dealing at arm's length and carrying on an unincorporated farming business, purchased farm equipment in a qualifying region for use...

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Words and Phrases
primarily

S4-F15-C1 - Manufacturing and Processing

Summary Under
Tax Topics - Income Tax Regulations - Regulation 5201 - Paragraph (a)

Application of "primarily"

1.21 ... [T]he term primarily as used in paragraph 5201(a) of the Regulations signifies principally or chiefly and...

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Words and Phrases
primarily

Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197

Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1)
offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply

The taxpayer (“Gerbro”) was a Canadian investment corporation (owned by a family trust but with an elderly income beneficiary, so that Gerbro...

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Words and Phrases
portfolio investment main reason primarily

Will Kare Paving & Contracting Ltd. v. The Queen, 98 DTC 6203 (FCA)

Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 39

The taxpayer purchased an asphalt plant with the expectation that it would sell up to 40% of the production of the plant to third parties and use...

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Words and Phrases
primarily

Plamondon v. The Queen, 2011 DTC 1137 [at at 746], 2011 TCC 47 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 54 - Personal-Use Property
each donated dried insect was separate property

Hogan J found that dried insects donated by the taxpayer to Laval University were individually appraised and did not "form an unbreakable set,"...

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Words and Phrases
use primarily

Burger King Restaurants of Canada Inc. v. Canada, 2000 DTC 6061 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property

Although Burger King restaurant were used for "processing" (given that the ordinary meaning of that word did not exclude the preparation of food),...

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Words and Phrases
primarily

Mother's Pizza Parlour (London) Ltd. v. The Queen, 88 DTC 6397, [1988] 2 CTC 197 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property

A Mother's Pizza restaurant, which devoted 25% of its floor area and 30% of its payroll to its kitchen, and the balance to the dining rooms and...

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Words and Phrases
primarily