Words and Phrases - "carry on"
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...
| 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...
| 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
Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Active Business Carried On by a Corporationquestion 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...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions | 83 |