Words and Phrases - "liability"

82
43
75
50
36
31
17
13
71
2
2
30
51
25
38
79
2
73
85
44
14
8
20
2
1

Barejo Holdings ULC v. Canada, 2020 FCA 47

the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity

An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
debt liability
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Consistency presumption of consistent expression is not absolute 252
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract 3 tests for what constituted debt under s. 94.1(1)(a) 300

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:

"Liability" v. "debt" (pp. 716-717)

The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
liability debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 39