Words and Phrases - "included"
13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits
The executor of the estate of the deceased annuitant of an RRSP trust was unaware of the RRSP, did not notify the issuer of the RRSP, and settled...
Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141
The taxpayer was an Australian resident who was taxed at the 15% long-term U.S. capital gains rate on his gains on disposal of U.S. oil and gas...
Quigley v. The Queen, 96 DTC 1057, [1996] 1 CTC 2378 (TCC)
The taxpayer argued that no imputed interest was required to be included in his income under s. 80.4(2) respecting shareholder advances because,...
4 November 2008 External T.I. 2008-0264181E5 - Income recognition and ACB - trust units
Where a corporation with an October 31 year end receives income distributions from an income trust in February and March 2007 and sells its units...
Langdon v. Canada, 2000 DTC 6203 (FCA)
The taxpayer was not entitled to claim a deduction under s. 20(1)(l) because the sale giving rise to the receivable had not been reported in his...
Delle Donne v. The Queen, 2015 TCC 150
The taxpayer made a loan, bearing interest at 25%, to a corporation ("SA") owned by his brother-in-law, which in turn lent the funds, at the same...
Everett's Truck Stop Ltd. v. The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)
The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's...