Subsection 141.1(1)
Subsection 141.1(2)
Paragraph 141.1(2)(a)
See Also
Aviva Canada Inc. formerly CGU Group Canada Ltd. v. The Queen, 2006 TCC 57
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity | purchase and immediate resale at the same FMV was not commercial activity | 207 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | purchase and immediate resale at the same FMV was not an adventure | 211 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Trademarks | purchase and immediate resale at the same FMV was not an adventure | 272 |
Subsection 141.1(3)
Paragraph 141.1(3)(a)
Cases
Onenergy Inc. v. Canada, 2018 FCA 54
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | no direct tracing to taxable supplies was required | 259 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | provision dealing with only certain situations was the more specific | 45 |
See Also
Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 171 - Subsection 171(3) | continued to be registrant following revocation of registration number | 300 |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) | winding-down operations qualified a de-registrant as a “registrant”/registration retroactive | 206 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Registrant | registrant based on wind-up activities | 60 |
ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA
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Administrative Policy
8 March 2018 CBA Commodity Tax Roundtable, Q.16
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 211 - Subsection 211(2) | s. 211 election applies on property-by-property basis/conditions for s. 211(2) application | 98 |
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23 ("Pre-incorporation Contract")
15 November 2011 Headquarters Letter Case No. 135608
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 171 - Subsection 171(1) | 124 | |
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(2) | 41 | |
| Tax Topics - Excise Tax Act - Section 240 - Subsection 240(3) - Paragraph 240(3)(a) | commencement of preliminary commercial activity | 140 |
Paragraph 141.1(3)(b)
See Also
Richter & Associates Inc v. The Queen, 2005 TCC 92
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Business | litigation support services provided by trustee for bankrupt financial institution were an "undertaking" | 269 |
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | allocation between costs incurred by trustee in bankruptcy for bankrupt financial institution to provide litigation services to creditors, and costs incurred in connection with its action qua trustee | 375 |
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(5) | allocation between own suit and litigation support | 68 |
| Tax Topics - Excise Tax Act - Section 265 - Subsection 265(1) - Paragraph 265(1)(f) | trustee's own suit and litigation support activity were related | 278 |
| Tax Topics - General Concepts - Illegality | Act applied to what has occurred irrespective of legality | 134 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | litigation support services provided by trustee for bankrupt financial institution were an "undertaking" | 270 |