Words and Phrases - "in connection with"
19 October 2004 Internal T.I. 2004-0094971I7 F - Programme de formation admissible
Summary UnderTax Topics - Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program
“period” referred to the times at which the individual was receiving income from employment
The Directorate indicated that the word “period” in the pre-2004 version of para. (b) of the definition of “qualifying educational...
Words and Phrasesperiod in connection with
ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA
Summary UnderTax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a)
services acquired long after the cessation of commercial activity may give rise to input tax credits
The appellant (“Look”), which had been carrying on a telecommunications business, sold its licences (including its “Spectrum” licence) ,...
13 January 2015 Internal T.I. 2013-0497361I7 F - Services performed by a foreign affiliate
prototype testing services not directly related to sales of improved product
A foreign affiliate ("FA1") of a Canadian manufacturer (the "Taxpayer") provides testing services to the Taxpayer on products (namely, prototypes)...
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|Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(d)||prototype testing services not manufacturing||123|
Reiner v. The Queen, 2005 DTC 308, 2005 TCC 115 (Informal Procedure)
The taxpayer, who was a full-time teacher, also was pursuing a course of studies at a U.S. university leading to a Master of Arts in Curriculum...