Words and Phrases - "acquire"
Thye RRSP of James T. Grenon (552-53721) by its Trustee CIBC Trust Corporation v. Canada, 2025 FCA 129
The appellant subscribed $310 million for units of various income funds, which were intended to qualify as mutual fund trusts on the basis that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.1 - Subsection 207.1(1) | since FMV of non-qualified investments was required to be included in the annuitant’s income (even though such inclusion was not reported or assessed) it was excluded from Pt. XI.1 tax | 360 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) | assessment of group RRSP return focused on Pt. XI.1 tax reporting did not start the Pt. I normal reassessment period running | 279 |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3) | FCA raised the correctness of (and reversed) a TCC finding that was not challenged by the parties | 420 |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) | RRSP must recognize losses on non-qualified investments but such losses, if capital losses, cannot be deducted from property income from such investments | 153 |
| Tax Topics - Statutory Interpretation - Consistency | presumption that same word has same meaning, and different words have different meanings throughout the ITA | 233 |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | meaning of “distribution” informed by provincial securities law | 161 |
| Tax Topics - Statutory Interpretation - French and English Version | 2-step approach to reconciling 2 versions | 298 |
31 July 2023 Internal T.I. 2021-0876331I7 - SR&ED ITC Recapture Rules
The taxpayer harvests trees, transforms then into logs, and feeds the logs into a new machine being tested for SR&ED purposes. The logs so used in...
GST New Memorandum 8.1, ITCs—General Eligibility Rules, May 2005
Meaning of “acquire”
9. The word “acquire” is not defined in the Act. The ordinary dictionary definition of the term “acquire” is to...
Regan M. Williams, Appellant v. Her Majesty the Queen, Respondent, 97 DTC 887, [1997] 2 CTC 2151 (TCC)
When the taxpayer exercised stock option rights, he did so as nominee for others. Accordingly, he had not "acquired" (i.e., obtained for himself)...
Canada v. Morin, 2006 DTC 6057, 2006 FCA 25
The taxpayer entered into an arrangement with a consultant ("Bobsan") under which Bobsan would recommend to him firms within the high-tech area to...
Kowdrysh v. The Queen, 2001 DTC 5221, 2001 FCA 34
Létourneau J.A. found that in the context of the temporary program for qualified small-business property, the proper interpretation of the word...
Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC)
The Quebec taxpayer was found to have "acquired" trucks pursuant to leases given that it had possession and use of the trucks, it had assumed all...
Canada v. General Motors of Canada Limited, [2009] GSTC 64, 2009 FCA 114
The Appellant (a car manufacturer) was the administrator of various defined benefit pension plans for its unionized employees. It was the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | 99 | |
| Tax Topics - Excise Tax Act - Section 267.1 - Subsection 267.1(2) | administrator of pension trust was not a trustee, and not subject to s. 267.1 | 51 |
| Tax Topics - Income Tax Act - Section 104 - Subsection 104(1) | administrator of pension trust was not a trustee | 41 |