Words and Phrases - "liable"

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14 September 2016 External T.I. 2016-0638171E5 - Liability under section 159

has potential personal liability for the maximum value of the property under its control from the moment that the taxpayer’s tax debt was assessed

The “Trustee” of a trust holds a portfolio of securities whose fair market value is $125,000 on December 31, 2014. The 2014 return of the sole...

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Words and Phrases
liable

The Queen v. National Trustco, 98 DTC 6409, [1998] 4 CTC 26 (FCA)

liability of trustee for collapsed RRSP amounts not paid pursuant to requirement was an amount for which it was "responsible at law"

The respondent was liable under s. 224(4) for its failure to respond to s. 224(1) demands (made both before and after the maturity of the GIC in...

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Words and Phrases
liable payable

Exida.Com Limited Liability Company v. Canada, 2010 DTC 5101, 2010 FCA 159

no substantive tax liability

A non-resident corporation which failed to file corporate income tax returns but which had no income taxes payable in Canada was not subject to...

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Words and Phrases
liable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) "penalty" does not include nil penalty 92
Tax Topics - Statutory Interpretation - Ordinary Meaning purposive interpretation must be consistent with words 93
Tax Topics - Statutory Interpretation - Territorial Limits no filing requirement if no connection with Canada 79

Exida.Com Limited Liability Company v. The Queen, 2009 DTC 1278, 2009 TCC 373 (Informal Procedure), rev'd above.

The taxpayer, which was a non-resident corporation that filed tax returns for the relevant taxation years late but with no tax owing, was liable...

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Words and Phrases
liable