Words and Phrases - "because of"
Ellison v Sandini Pty Ltd, [2018] FCAFC 44
subjective belief of parties that family court orders were efficacious did establish that a share transfer to a spouse occurred “because of” them
Australian Family Court orders, that were made by consent between Mr and Ms Ellison, required a corporation (“Sandini” - that was controlled...
Words and Phrases
because of| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Ownership | family court order requiring the transfer of a portion of a larger bloc of shares likely did not result in a change in their beneficial ownership as the shares likely were not fungible | 1019 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | family court order did not effect a change in beneficial ownership of a larger bloc of shares held by the original owner (and in any event, the order named the wrong person) | 768 |
| Tax Topics - General Concepts - Evidence | a court order could not be interpreted in light of extrinsic evidence | 102 |
Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32
Meaning of “because of” in s. 18(6)(c)(i) (p. 26:8)
While the Supreme Court's comments in Copthorne appear to soften the "strong causal...
Words and Phrases
because ofAttorney General of Canada v. Hoefele, 95 DTC 5602, [1996] 1 CTC 131 (FCA)
new mortgage debt of relocated employees
Employees of Petro-Canada who were required to relocate from Calgary to Toronto had a declining percentage of their increased interest costs...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Tax Avoidance | form matters | 82 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | interest rate subsidy did not increase net worth | 102 |
Williams v. The Queen, 2011 DTC 1087 [at 480], 2011 TCC 66 (Informal Procedure)
no strong causal connection between the employment and occupation of accommodation
The taxpayer and her husband were both members of the clergy who ministered to a congregation. The taxpayer's husband's housing allowance covered...