Words and Phrases - "bona fide"
7 April 2022 CBA Roundtable, Q.5
medical fee-sharing policy based on there also being an exempt medical supply by the sub-contracted medical supplier to the other
P-238 discusses fee sharing in the context of a practice involving a principal practitioner and a locum, and involving a principal practitioner...
Words and Phrases
bona fide| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | there can be a double supply of a physician’s services | 172 |
Cassan v. The Queen, 2017 TCC 174
Summary Under
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a)loans were not bona fide in that not handled with commerciality
In December 2009, individual taxpayers participated in a tax shelter that involved making both a leveraged investment (the "LP Program") and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | common law gift was vitiated by loan to donor at unreasonably low rate | 793 |
| Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) | although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance | 478 |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) | no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable | 605 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time | 619 |
| Tax Topics - Statutory Interpretation - Realization Principle | amount should not be recognized until ascertainable | 73 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | gratuitous transfer is gift irresepctive of absence of benevolent intent | 56 |
Extendicare Health Services Inc. v. MNR, 87 DTC 5404, [1987] 2CTC 179 (FCTD)
"[T]he term 'bona fide', when used as an adjective, is generally taken to mean 'honestly', 'genuinely' or 'in good faith'."
Words and Phrases
bona fide| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | 43 |
Tolhoek v. The Queen, 2007 DTC 247, 2006 TCC 681 (Informal Procedure), aff'd 2008 FCA 128
A partnership ("ICON") of which the taxpayer became a limited partner purchased software from a subsidiary ("Trafalgar Capital") of the developer...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(15) | 62 |