Words and Phrases - "property"

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15 March 2005 Internal T.I. 2004-0108721I7 F - Don d'une licence

excepting WIP, definition of property is no broader than term’s ordinary meaning

In connection with finding that a gift of a non-exclusive software licence was a gift of property, CRA stated:

In Manrell, the Court went on to...

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Words and Phrases
property
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts gift of a non-exclusive software licence was a gift of property 105

Aitchison Professional Corporation v. The Queen, 2018 TCC 131

s. 160(1) did not apply to a tax debtor providing services free of charge to the NAL transferee of his professional practice

At a time that James Aitchison owed $2.1 million in taxes, he transferred his law practice to a newly-incorporated professional corporation (the...

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Words and Phrases
property
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property (foregone) right to negotiate a significant salary was not property 169

Nokes v. Doncaster Amalgamated Collieries Ltd., [1940] A.C. 1014 (HL)

It was held that where a court order was made under the Companies Act 1929, for the amalgamation of two corporations, including an order for the...

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Words and Phrases
property property acquired

Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128

"property" entails an exclusive right

A portion of the consideration paid by a purchaser of shares of operating companies in which the taxpayer had been a significant shareholder...

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Words and Phrases
property

The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209

"property" includes a contract right, or potentially covenant to deliver knowhow

Estey, J. found that the interpretation of the initial version of s. 68 should be interpreted in light of the broad meaning of "property," in s....

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Words and Phrases
property

Medland v. Canada, 98 DTC 6358, [1999] 4 CTC 293 (FCA)

There was a transfer of property to the taxpayer for purposes of s. 160(1) when her husband, who was the joint mortgagor on a house that at the...

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Words and Phrases
property property acquired

Location Gaétan Lévesque Inc. v. MNR, 91 DTC 1380, [1991] 2 CTC 2795 (TCC)

The taxpayer entered into "leasing contracts" respecting heavy equipment which typically had a term of approximately five years, provided for...

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Words and Phrases
property property acquired
Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership lessee with purchase option not the beneficial owner 117