Words and Phrases - "belong"
9 July 2024 Internal T.I. 2023-0976691I7 - Film Tax Credit and Alter Ego Trust
Summary Under
Tax Topics - General Concepts - Ownershipthe property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust
In order for a fee paid to a corporation for the executive producer servicers of an individual employed by the corporation to qualify for the B.C....
Words and Phrases
belongLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 125.4 - Subsection 125.4(1) - Labour Expenditure - Paragraph (b) - Subparagraph (b)(iii) | shares of sole-shareholder corporation “belonged” to the individual who was the trustee and life beneficiary of the alter ego trust holding those shares, rather than to the trust | 270 |
Distillers Corp - Seagrams Ltd v. MNR, 80 DTC 1649 (T.R.B.)
An indirect subsidiary of the taxpayer did not qualify as a subsidiary controlled corporation given that "the word 'belong' means that the shares...
Words and Phrases
belongLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Subsidiary Controlled Corporation | 33 |
Re City of Kitchener and Regional Assessment Commissioner for Regional Municipality of Waterloo (1978), 23 OR (2d) 190 (Ont. D. Ct.)
A property that a municipality had sold to a developer, and leased back from the developer under a net lease that provided that the property would...
Words and Phrases
belong