Words and Phrases - "real property"
22 June 2001 Internal T.I. 2001-0078457 F - Décret remise d'impôt revenu gagné au Québec
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (a)gold royalty was neither TCP nor real property
A non-resident inherited a royalty entitlement to a percentage of the net proceeds of sales from a Quebec gold mine, and then sold the royalty to...
Words and Phrases
real property17 May 2021 Internal T.I. 2020-0870041I7 - CERS - Meaning of Qualifying Property
Summary Under
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Propertya property can be bifurcated into a qualifying property and a residence for CERS purposes
Regarding queries as to whether the determination of a property as a qualifying property for Canada emergency rent subsidy (“CERS”) purposes...
Words and Phrases
real propertyResource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51
Art. 6 extends common law meaning of real property
Art. VI of the Australia-U.S. Convention defined real property to include “rights to exploit or to explore for natural resources.” In...
Words and Phrases
real property| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | private equity fund LP with 5-year holding objective realized share gain on income account | 175 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia | 427 |
| Tax Topics - Treaties - Income Tax Conventions - Article 3 | each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise” | 234 |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild | 420 |
| Tax Topics - General Concepts - Stare Decisis | lower court not bound by a point of law that was assumed rather than examined by a higher court | 292 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | assessment of partnership was assessment of partners | 89 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) | shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property | 514 |
| Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment | shares of Australian mining company were primarily attributable to the processing rather than mining operations | 142 |
| Tax Topics - General Concepts - Fair Market Value - Other | processing assets of mining company were more valuable than its mining assets | 238 |
1 March 2016 Internal T.I. 2016-0631181I7 - Specified foreign property - mineral rights
Summary Under
Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Propertymineral right is real property which is intangible property
After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of...
Notice 269 – Draft GST/HST Memorandum 3.7, "Natural Resources" 15 February 2012
Overview of section 162
1. Section 162 deems the following supplies of natural resource property rights not to be supplies for GST/HST...
Words and Phrases
explore exploit mineral royalty interest gross overriding royalty working interest real property