Words and Phrases - "source"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

Gulf Canada Resources Ltd. v. The Queen, 95 DTC 5189, [1995] 1 CTC 334 (FCTD), partially rev'd 96 DTC 6065 (FCA).

Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs

Before going on to find that the taxpayer's interest in the Syncrude project did not constitute a "source" of income for its 1978 taxation year, McKeown J. stated (at p. 5202):

"In my view, a 'source' of income comes into existence only when all of the activities making up the 'source' are being carried on ... . I find that in 1978 Syncrude was not capable of being operated on a scale which could be expected to be profitable in 1978 or the near future."

Words and Phrases
source