Words and Phrases - "fixture"

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26 May 2022 External T.I. 2019-0813761E5 - Taxable Canadian property-solar and wind projects

solar equipment assembly was a fixture under the common law tests

Were Canadian-situs solar electric power generating projects (consisting of a leasehold interest, solar panels, steel racks and metal posts, and...

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Words and Phrases
fixture
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (a) commercial solar equipment and wind turbines were Canadian real estate and, thus, TCP 441

7 April 2022 CBA Roundtable, Q.3

two annexation tests for determining whether personal property has become a fixture

CRA confirmed that since appliances and common area furniture and equipment that are acquired in connection with the construction of, say, a...

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Words and Phrases
fixture
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 191 - Subsection 191(3) no ITCs for appliances acquired during the construction of a rental residential complex 201

16 May 2017 External T.I. 2016-0670661E5 - Capital Cost of De-icing Equipment

ice-melting shingles beneath solar equipment likely “related” to such equipment and not an accession to the building

New aluminum shingles with an electric cable (the “Equipment”) will be attached over existing asphalt shingles on the portion of a roof...

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Words and Phrases
related fixture

Zellstoff Celgar Limited v. British Columbia, 2014 BCCA 279

pulp mill equipment was permanently annexed and for use of land

The machinery and equipment in a pulp mill purchased by the taxpayer was fixtures and, therefore subject to land transfer tax under the Property...

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Words and Phrases
fixture

Stack v. T. Eaton Co., [1902] O.J. No. 155 (Div. Ct.)

After reviewing the then-leading decisions (including Bain v. Brand (1876), 1 App. Cas. 762, Holland v. Hodgson (1872), L.R. 7 C.P. 328, Hobson v....

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Words and Phrases
fixture

Ontario Hydro v. Ontario (Ministry of Revenue), [1996] O.J. No. 333, 60 A.C.W.S. (3d) 1080, aff’d on other grounds [1999] O.J. No. 1723, 44 O.R. (3d) 1, 120 O.A.C. 184, 88 A.C.W.S. (3d) 507

microwave equipment which did not improve a building was not fixtures

Borins J found that microwave telecommunications and power line carrier equipment which for the most part was attached by screws to metal racks...

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Words and Phrases
fixture