Words and Phrases - "carry on"

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19 October 2023 Internal T.I. 2020-0856851I7 - Ordinary Course of Business

MRPS acquired by a Canadian insurance company subsidiary in order for the Luxco to loan-finance US operations were not acquired in the ordinary course

In 2010, a Canadian corporation, which was a specified financial institution by virtue of being controlled by its parent, a Canadian insurance...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(2.1) MRPS used to finance US opco or opco acquisition were not acquired in the ordinary course of the business 360

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 5, 2022-0936301C6 F - Guarantee fee

guarantee or pledge fee is from a service and, therefore, is from an undertaking of any kind whatever

An individual, a sole shareholder of a corporation, borrows money in order to earn business or property income. To secure his personal loan, his...

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Words and Phrases
undertaking carry on service
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) one-time fee to subsidiary for mortgaging its property as security for a bank loan to the shareholder would not qualify under s. 20(1)(e.1) 139
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) one-time fee to subsidiary for mortgaging its property as security for a bank loan to the shareholder could qualify under s. 20(1)(e) 175
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) no shareholder benefit where corporation receives a reasonable pledge (or “guarantee”) fee from its shareholder 124

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F - entreprise exploitée activement – revenu de location

question of fact whether a CCPC with too many employees to have a specified investment business carries on a business

Realtyco is a CCPC holding in Canada six buildings each containing 50 residential units, which it rents out. The sole services provided by it to...

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Words and Phrases
carry on
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business principal purpose means main or chief objective 143

Thiel v. Federal Commissioner of Taxation, 90 A.TC 4717 (HC of A.)

"enterprise" includes an isolated adventure

In January and May 1984 the taxpayer, who was a resident of Switzerland, paid $150,000 to acquire six units in the Energy Research Group Unit...

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Words and Phrases
enterprise carry on
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions 83