Words and Phrases - "in the course of"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

President's Choice Bank v. Canada (the King), 2024 FCA 135

Summary Under
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(5)
loyalty point redemption payments made in the course of a financial business could generate ITCs if also in the course of a commercial activity

A corporation (“PC Bank”) in the Loblaw group, whose business was to grant credit through the operation of a MasterCard program, obtained the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) s. 169(1) requires apportionment of an acquisition of a property or service between commercial and exempt activity 72
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Commercial Activity commercial activity of corporation can be at a loss 144

25 April 2002 Internal T.I. 2002-0131937 F - FRAIS D'EMPRUNT-EVALUATION ARPENTAGE

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(ii)
cost of appraisal fee required by mortgage lender was deductible

A taxpayer who used a second-mortgage loan on the individual’s residence to make interest and dividend-generating investments, was required by...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of

Glencore Canada Corporation v. Canada, 2024 FCA 3

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)
break fee was includible under s. 12(1)(x)

An integrated nickel-mining public company (“Falconbridge”), entered into merger agreements with a more junior public company (“Diamond...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
inducement in the course of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments break fee was a capital receipt 188
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property break fee was not consideration for the disposition of a merger right as there was no such “right” 215
Tax Topics - Income Tax Act - Section 54 - Capital Property break fee was not proceeds of disposition of a capital property 176

7 April 2022 CBA Roundtable, Q.14

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 2 - Paragraph 2(a)
zero-rating under s. 2(a) for supplies to an airline relates to connected property or services, but not to the aircraft itself

Does Sched. VI, Pt. V, s. 2 zero-rate all property that is purchased or leased by a non-resident airline whose sole activity is to carry on the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of

28 April 2004 Internal T.I. 2004-0066991I7 F - Paiement incitatif

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)
incentive payments received from broker to purchase an exempt life insurance policy were received “in the course of earning income from … property” (the policy)

As an incentive for the sale of exempt life insurance policies (having a savings and investment component) a life insurance brokers would pay to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of in the course of earning income from … property
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property property “includes practically any type of economic interest” 142
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose per MacIntyre, life insurance premiums are not deductible from business income 192

MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e)

In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
commission in the course of

Higgs v. Olivier (1952), 33 TC 136 (C.A.)

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x)

Before going on to find that a lump sum received by an actor in consideration for his covenant not to exercise his vocation for a period of 18...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of

Blok-Andersen v. MNR, 72 DTC 6309, [1972] CTC 338 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 112 - Subsection 112(2.1)

In the course of considering a submission that s. 85B(1)(B) of the pre-1972 Act (now s. 12(1)(b)) did not apply to an adventure in the nature of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
in the course of