Words and Phrases - "enterprise"
Wolf v. The Queen, 2018 TCC 84, aff'd on evidentiary grounds 2019 FCA 283
revenues earned by an individual through an LLC could be included in determining what were his business revenues for services-PE purposes
The taxpayer, an aerospace engineer and a U.S. resident, was hired as an independent contractor for TDM Technical Services, a temporary employment...
Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51
each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise”
Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of...
Words and Phrases
enterprise| 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 | 175 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia | 427 |
| 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 | 420 |
| 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 | 292 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | assessment of partnership was assessment of partners | 89 |
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | Art. 6 extends common law meaning of real property | 198 |
| 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 | 514 |
| 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 | 142 |
| Tax Topics - General Concepts - Fair Market Value - Other | processing assets of mining company were more valuable than its mining assets | 238 |
14 December 2015 Internal T.I. 2014-0558661I7 - Application of Article V(9) to a partnership
services PE of U.S. partnership based on collective Canadian activities of all partners
Mr. A and Mr. B, both U.S. resident individuals, are partners of a U.S. partnership (which is fiscally transparent in the U.S.) that provides...
Words and Phrases
enterpriseThiel v. Federal Commissioner of Taxation, 90 A.TC 4717 (HC of A.)
"enterprise" includes an isolated adventure
In January and May 1984 the taxpayer, who was a resident of Switzerland, paid $150,000 to acquire six units in the Energy Research Group Unit...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions | 83 |