Words and Phrases - "licence or similar arrangement"

a
88
b
44
c
78
d
52
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

Daruwala v. The Queen, 2012 TCC 257 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 2 - Subsection 2(1)

Woods J. stated (at paras. 25-26):

The term "residence" has a flexible meaning which is dependant on the context in which it is used. ...

The term "residence" as used in the context of Thomson applies in determining the liability of an individual to income tax. The focus in this context is on the individual rather than on a property and a myriad of personal factors involving the person's customary mode of living are looked at. This include things such as social and economic ties. It does not make any sense to apply this test in the context of s. 191(1) [of the Excise Tax Act].

The context of s. 191(1) was to make the builder of a substantially completed complex liable for GST if it arranged to lease or license the complex to an individual as a place of residence.

Words and Phrases
residence licence or similar arrangement
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 191 - Subsection 191(1) informal arrangement included 168