Words and Phrases - "directly or indirectly"

61
27
44
35
26
22
11
8
52
1
2
18
36
20
28
59
1
49
58
33
7
7
10
1

Louie v. The Queen, 2018 TCC 225

temporal limitation placed on the advantages considered to arise from TFSA swap transactions

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Words and Phrases
directly or indirectly
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) share swap transactions were series notwithstanding that their particulars and end point were not known in advance 181
Tax Topics - Income Tax Act - Section 207.05 - Subsection 207.05(3) holder rather than trustee liable for advantage tax 146
Tax Topics - General Concepts - Fair Market Value - Shares use of price range for share valuation was inappropriate where there was a second-by-second market 171

Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51

gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares private equity fund LP with 5-year holding objective realized share gain on income account 167
Tax Topics - Treaties - Income Tax Conventions - Article 3 each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise” 222
Tax Topics 386
Tax Topics - Treaties - Income Tax Conventions - Article 13 exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild
Tax Topics - General Concepts - Stare Decisis lower court not bound by a point of law that was assumed rather than examined by a higher court 272
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) assessment of partnership was assessment of partners 83
Tax Topics - Treaties - Income Tax Conventions - Article 6 Art. 6 extends common law meaning of real property 180
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property 500
Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment shares of Australian mining company were primarily attributable to the processing rather than mining operations 140
Tax Topics - General Concepts - Fair Market Value - Other processing assets of mining company were more valuable than its mining assets 234

Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017

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