Cases
Stewart v. Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 S.C.R. 645
Before finding that the taxpayer was not required to establish that he had a reasonable expectation of profit ("REOP") with respect to four rental...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | not tainted by capital gains motivation | 115 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | "business" has its broad common law definition | 95 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Personal or Living Expenses | 12 | |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | no reasonable expectation of profit test if no personal element | 353 |
Canderel Ltd. v. R., 98 DTC 6100, [1998] 1 S.C.R. 147, [1998] 2 C.T.C. 35
Iacobucci J found that it was inappropriate to require the amortization over time of tenant inducement payments made by the taxpayer given that,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 105 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 57 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | not following matching principle accorded with well-accepted business practices | 153 |
| Tax Topics - Income Tax Act - Section 9 - Timing | lease inducement payments currently deductible | 124 |
| Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | inference made from narrow scope of s. 18(9) | 34 |