Words and Phrases - "elects ... in the taxpayer's return"
Rezek v. Canada, 2005 DTC 5373, 2005 FCA 227
s. 39(4) elections that were made with late-filed returns were valid as being made "in the taxpayer's return"
After confirming the Minister's position that the taxpayer and his wife were engaged in spread transactions as a partnership, and therefore that...
Locations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | impermissible new theory | 45 |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | spread comprising a convertible security and rights under short sale was not a single property | 129 |
Tax Topics - Income Tax Act - Section 39 - Subsection 39(4) | requirement to file election with return is satisfied even if return is late | 144 |
Tax Topics - Income Tax Act - Section 96 | spouse carrying on linked legs of integrated trading transactions | 204 |
Tax Topics - Statutory Interpretation - Resolving Ambiguity | 54 |