Words and Phrases - "disposition"

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17 February 2016 External T.I. 2015-0608261E5 - Splitting of a Multiple Life Insurance Policy

disposition where change going to root of policy

Respecting the exercise by a policyholder of a contractual right to split a universal life insurance policy covering two lives into two policies,...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(10) - Paragraph 148(10)(d) s. 148(10)(d) does not apply to the exercise of a right to split an insurance policy 256

Buccini v. Canada, 2000 DTC 6685 (FCA)

Following the amalgamation of the taxpayer's employer with other Canadian subsidiaries of the U.S. parent, the taxpayer executed a settlement...

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Words and Phrases
disposition

The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209

The phrase "the disposition of any property" means the sale of a particular item or items of property and "the expression 'something else' must be...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property "property" includes a contract right, or potentially covenant to deliver knowhow 78
Tax Topics - Statutory Interpretation - Context 27

In re Barne Crown Ltd., [1995] 1 WLR 147 (Ch. D.)

The Court found that in collecting payment upon a cheque from a third party, no disposition of the property of the customer takes place in favour...

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Words and Phrases
disposition

Quincaillerie Laberge Inc. v. The Queen, 95 DTC 155 (TCC)

amendment of agreement did not entail its transfer

A payment of $575,000 to the taxpayer by a debtor in default in consideration for an extension of the due date of the loan and the taxpayer's...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) amount received for loan extension 156

The Queen v. Harvey, 83 DTC 5098, [1983] CTC 63 (FCTD)

disposition of property to corporation even though property extinguished

The taxpayer was found to have disposed of his stock option rights to a corporation for purposes of s. 7(1)(b) when he agreed to surrender them...

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Words and Phrases
disposition

Hewlett Packard (Canada) Ltd. v. Canada, 2004 DTC 6498, 2004 FCA 240

no disposition until change in beneficial ownership

The taxpayer (who had an October 31 fiscal year end) followed a practice of purchasing a new fleet of cars from Ford to replace the fleet which it...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Provincial Law 89

Borstad Welding Supplies (1972) Ltd. v. The Queen, 93 DTC 5457, [1993] 2 CTC 266 (FCTD)

no transfer of title or all the incidents of title

In connection with the sale of the taxpayer's business to an arm's length corporation, it was agreed that refillable cylinders would be rented by...

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Words and Phrases
disposition

Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)

complete divesting of all the benefits and burdens of ownership

It was held that since the taxpayer, by executing an agreement respecting the ultimate sale by it of apartment buildings, had "completely divested...

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Words and Phrases
disposition
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing 78