because of

Ellison v Sandini Pty Ltd, [2018] FCAFC 44 -- summary under Paragraph 73(1)(b)

Full Title
Ellison v Sandini Pty Ltd, [2018] FCAFC 44
Summary Under
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) - Paragraph 73(1)(b)
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...

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Words and Phrases
because of

Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32 -- summary under Subparagraph 18(6)(c)(i)

Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(c) - Subparagraph 18(6)(c)(i)

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...

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Words and Phrases
because of

Attorney General of Canada v. Hoefele, 95 DTC 5602, [1996] 1 CTC 131 (FCA) -- summary under Subsection 80.4(1)

Full Title
Attorney General of Canada v. Hoefele, 95 DTC 5602, [1996] 1 CTC 131 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1)
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...

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Words and Phrases
as a consequence of
because of

Williams v. The Queen, 2011 DTC 1087 [at at 480], 2011 TCC 66 (Informal Procedure) -- summary under Paragraph 6(1)(a)

Full Title
Williams v. The Queen, 2011 DTC 1087 [at at 480], 2011 TCC 66 (Informal Procedure)
Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)
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...

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Words and Phrases
because of
in the course of employment
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