Words and Phrases - "primarily"
GST/HST Memorandum 3-3-5-1 “Place of Supply in a Province Specific Rules for Intangible Personal Property” January 2025
Determination of ordinary location by agreement
17. The place of supply rules for intangible personal property that relate to tangible personal...
Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160
In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 280 - Subsection 280(1) - Paragraph 280(1)(a) | due diligence defence established based on reasonable filing position | 55 |
24 April 2002 External T.I. 2001-0095755 F - TÉLÉTRAVAIL
The Employe is now permitting employees to choose to perform their duties from home (“telework”) so that employees can perform the tasks...
16 July 2021 Internal T.I. 2020-0872521I7 - CERS - Qualifying property for rental income
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...
20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole
Two taxpayers, dealing at arm's length and carrying on an unincorporated farming business, purchased farm equipment in a qualifying region for use...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(27) | no ITC reversal if unanticipated transfer of equipment to a farm outside the region | 172 |
| Tax Topics - General Concepts - Ownership | co-owners entitled to pro rata ITCs | 63 |
S4-F15-C1 - Manufacturing and Processing
Application of "primarily"
1.21 ... [T]he term primarily as used in paragraph 5201(a) of the Regulations signifies principally or chiefly and...
Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197
The taxpayer (“Gerbro”) was a Canadian investment corporation (owned by a family trust but with an elderly income beneficiary, so that Gerbro...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | no taxpayer burden to displace assumptions of mixed fact and law | 71 |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | Minister's statement was false | 130 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) | expert's report did not include all the underlying data | 115 |
Will Kare Paving & Contracting Ltd. v. The Queen, 98 DTC 6203 (FCA)
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...
Plamondon v. The Queen, 2011 DTC 1137 [at at 746], 2011 TCC 47 (Informal Procedure)
Hogan J found that dried insects donated by the taxpayer to Laval University were individually appraised and did not "form an unbreakable set,"...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 46 - Subsection 46(3) | 83 |
Burger King Restaurants of Canada Inc. v. Canada, 2000 DTC 6061 (FCA)
Although Burger King restaurant were used for "processing" (given that the ordinary meaning of that word did not exclude the preparation of food),...
Mother's Pizza Parlour (London) Ltd. v. The Queen, 88 DTC 6397, [1988] 2 CTC 197 (FCA)
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...