Words and Phrases - "donative intent"
Cassan v. The Queen, 2017 TCC 174
Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Giftscommon law gift was vitiated by loan to donor at unreasonably low rate
In December 2009, the taxpayers participated in a program that had both an investment and gifting component. The investment program entailed each...
Words and Phrases
donative intentLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) | although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance | 478 |
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) | loans were not bona fide in that not handled with commerciality | 701 |
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) | no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable | 605 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time | 619 |
Tax Topics - Statutory Interpretation - Realization Principle | amount should not be recognized until ascertainable | 73 |
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | gratuitous transfer is gift irresepctive of absence of benevolent intent | 56 |