Words and Phrases - "because of"

a
88
b
44
c
79
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

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
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

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
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
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 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