Words and Phrases - "for"
Marin v. The Queen, 2022 TCC 49
Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Taxtaxes for which FTC accorded must be imposed on the income which generates the Canadian taxes from which the credit is claimed
The taxpayer, a Canadian resident, was generally subject to French income tax on the rental income from a French property to the extent of his...
Words and Phrases
for| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | may-be-taxed language does not confer an exclusive right to tax | 195 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned | 193 |
| Tax Topics - Treaties - Income Tax Conventions - Article 24 | Art. 23 of French Treaty inapplicable where income of a particular taxation year was not otherwise taxed twice | 246 |
Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65
no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services
In 1998 the Canadian taxpayer paid $14.3 million to non-resident service providers in the ordinary course of its forestry business. The Minister...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation | narrow construction of Reg. so as to be intra vires | 212 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 | "in respect of" in Regulation read narrowly to conform with "for" in statute | 169 |