Words and Phrases - "for"

82
43
75
50
36
31
17
13
71
2
2
30
51
25
38
79
2
73
85
44
14
8
20
2
1

Marin v. The Queen, 2022 CCI 49

taxes for which FTC accorded must be imposed on the income which generates the Canadian taxes from which the credit is claimed

The taxpayer, a Canadian resident, was generally subject to French income tax on the rental income from a French property to the extent of his...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
for
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 6 may-be-taxed language does not confer an exclusive right to tax 195
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned 193
Tax Topics - Treaties - Income Tax Conventions - Article 24 Art. 23 of French Treaty inapplicable where income of a particular taxation year was not otherwise taxed twice 246

Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65

no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services

In 1998 the Canadian taxpayer paid $14.3 million to non-resident service providers in the ordinary course of its forestry business. The Minister...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
for in respect of retainer fee
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation narrow construction of Reg. so as to be intra vires 212
Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 "in respect of" in Regulation read narrowly to conform with "for" in statute 169