Cases
Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51, [2021] 3 S.C.R. 687
In finding that the business of a Barbados subsidiary of the taxpayer was not a “business conducted principally with persons with whom [it did]...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | “business conducted,” as contrasted to “business,” did not include the raising of capital | 229 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) | bank business was conducted with arm's length persons notwithstanding that capital raised from shareholder | 581 |
| Tax Topics - Statutory Interpretation - Certainty | full effect should be given to Parliament’s precise and unequivocal words to produce certainty | 88 |
| Tax Topics - Statutory Interpretation - Speaking in vain | Parliament does not speak in vain | 72 |
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(1) | two policies balanced in FAPI regime | 79 |
| Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | specific addition of a competition requirement in another provision implied that there was no such requirement here | 152 |
Administrative Policy
21 June 2016 Internal T.I. 2015-0581151I7 - Dutch Co-Op Entity Classification
Before going on to find that a Netherlands cooperative was a corporation for ITA purposes, the Directorate stated:
[T]he appropriate approach to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | Dutch co-op a corporation | 74 |
| Tax Topics - Income Tax Act - Section 96 | Dutch co-op a corp., not partnership | 45 |
23 April 2013 Internal T.I. 2012-0466081I7 F - Usufruct created under French legislation
Before finding that a gift of real property subject to the reservation of a usufruct under French law was to be treated under ITA s. 43.1 in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 43.1 | gift of immovable subject to reservation of a usufruct gave rise to a disposition under s. 43.1 | 282 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | disposition of all building under shared gift | 277 |
24 March 2004 External T.I. 2003-0034311E5 - "liquidation and a dissolution": What does it mean
The Agency was advised that under the corporate law of the Czech Republic, there was a distinction between a wind-up with liquidation of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(e) | process of distributing the assets and satisfying the liabilities is "liquidation" | 275 |
| Tax Topics - Statutory Interpretation - Provincial Law | 70 |