1.15 For income tax purposes, the term all or substantially all is understood to mean at least 90%, and the terms principally and primarily to...

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End of year references taxpayer

1.23 ... [T]he end of the tax year refers to the tax year of the taxpayer making the subsection 50(1) election....

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can be dissimilar business

1.30 ... [T]he business that commences to be carried on within the 24-month window need not be the same as (or even...

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Relevance of NAL relationship

1.34 ... While there is no legal requirement that in all cases a taxpayer must exhaust all legal means of collecting...

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1.46 ... Where a shareholder provides a guarantee or loan to a corporation in order to provide it capital, a clear connection will generally exist...

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1.64 ... In the 2015 tax year, Mr. R has a capital loss of $300,000 from a disposition of a debt that was owing to him ... an SBC [that] qualifies...

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1.71 ... Where an estate realizes a business investment loss in its first tax year, the legal representative of the estate may elect under...

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