Words and Phrases - "in relation to"

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Potash Corporation of Saskatchewan Inc. v. The Queen, 2022 TCC 75, aff'd 2024 FCA 35

sales of potash “related to” potash production

The taxpayer, which produced and sold potash from mines in Saskatchewan, was subject to both a profit tax and to the making of “base payments”...

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Words and Phrases
in relation to relates to
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose deductibility of Saskatchewan potash tax “base payments” denied given that sales they were applied to were a proxy for income 357

Westcoast Energy Inc. v. Canada, 2022 FCA 57

health care services rendered to employees were not in relation to the employer’s activities

Westcoast reimbursed (through Manulife as its agent) employees who had incurred various health care services – including some which were...

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Words and Phrases
in relation to
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 170 - Subsection 170(1)) - Paragraph 170(1)(b) - Subparagraph 170(1)(b)(ii) s. 170(1)(b)(ii) did not apply to reimbursed employee health care services as the services were acquired by the employees rather than the employer 201

Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151

s. 142(1)(d) only applies to a supply exclusively re real property

The members of the Appellant (which was a non-share Delaware corporation resident in Canada) included Canadian and U.S.-resident individuals who...

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Words and Phrases
in relation to
Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent 377
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service payment of condo operating expenses was a service 211
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of covering all time share operating costs 172
Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) GST collectible based on invoicing times 79
Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) objecting to quantum was sufficient particularity 177
Tax Topics - General Concepts - Ownership beneficial owner did not transfer property risk 183
Tax Topics - General Concepts - Evidence foreign law assumed the same 101

Miedzi Copper Corporation v. The Queen, 2015 TCC 26 (Informal Procedure)

all expenses of a pure holdco related to its subsidiary investment

Essentially the appellant's only activity was to indirectly finance the mineral exploration activities of six Polish subsidiaries of its immediate...

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Words and Phrases
in relation to

ExxonMobil Canada Ltd. v. Canada, 2010 FCA 1

the "supplies of property or services which the allowances were intended to fund...were for the exclusive personal use of the employees", rather than the employer

The appellants were required to relocate their employees to different locations as part of their business. In addition to reimbursing direct...

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Words and Phrases
allowance in relation to

Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285

"acquisition" of shares includes cancellation of those shares on a Delaware merger; "in relation to" to be construed broadly

The appellant acquired a US public company ("Keith") in a Delaware merger (in which Keith Industries merged into the appellant's US subsidiary,...

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Words and Phrases
in relation to acquisition
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) listing fees to issue shares to target shareholders were eligible 263

GST/HST memorandum 9.4 "Reimbursements" June 2012

15. However, if a person is an employee, a partner or a volunteer at the time the property or service is acquired, imported or brought into a...

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Words and Phrases
in relation to

12 December 2012 Interpretation Case No. 142112

"in relation to" includes appraising, physically protecting, securing, enhancing value, leasing or transferring

A real estate broker based in Nova Scotia is hired by a company with a head office in Nova Scotia to lease real property in New Brunswick to a...

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Words and Phrases
in relation to