Words and Phrases - "included"

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38
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13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits

benefit includible in deceased annuitant’s return was not subject to "benefit"-(a) exclusion because it was not reported

The executor of the estate of the deceased annuitant of an RRSP trust was unaware of the RRSP, did not notify the issuer of the RRSP, and settled...

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Words and Phrases
included
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) s. 146(8) benefit paid to the taxpayer’s administrator was not includible in her income until the year she was identified and received the amount 377
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(c) tax imposed on RRSP under s. 146(4)(c) where RRSP issuer unaware of annuitant’s death 187
Tax Topics - General Concepts - Payment & Receipt constructive receipt of amount deducted on account of fees that were the recipient’s obligation 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees incurred as a consequence of receiving unclaimed property (which was taxable under s. 146(8)) were non-deductible 205
Tax Topics - Income Tax Act - Section 9 - Timing receipt of income by an administrator was not income of the beneficial owner until the year she was identified 350

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141

a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income

The taxpayer was an Australian resident who was taxed at the 15% long-term U.S. capital gains rate on his gains on disposal of U.S. oil and gas...

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Words and Phrases
in respect of included
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 24 foreign tax credit was not required to be accorded to all the US tax on the gain 361

David Nathanson, "Included Versus Reported", Canadian Tax Highlights, Vol. 24, No. 9, September 2016, p. 5

Quigley treats “included” as “reported” or “assessed” (p. 5)

[T]he [Quigley] decision assumes that "included" means "reported" or...

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Words and Phrases
included

Quigley v. The Queen, 96 DTC 1057, [1996] 1 CTC 2378 (TCC)

The taxpayer argued that no imputed interest was required to be included in his income under s. 80.4(2) respecting shareholder advances because,...

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Words and Phrases
included

4 November 2008 External T.I. 2008-0264181E5 - Income recognition and ACB - trust units

amount paid to beneficiary "was included" in its taxation year in which trust's taxation year ends/beneficiary return for previous year re-opened to avoid double taxation

Where a corporation with an October 31 year end receives income distributions from an income trust in February and March 2007 and sells its units...

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Words and Phrases
included

Langdon v. Canada, 2000 DTC 6203 (FCA)

The taxpayer was not entitled to claim a deduction under s. 20(1)(l) because the sale giving rise to the receivable had not been reported in his...

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Words and Phrases
included

Delle Donne v. The Queen, 2015 TCC 150

doubtful debt reserve claimed implicitly as at the year end in light of subsequently revealed information

The taxpayer made a loan, bearing interest at 25%, to a corporation ("SA") owned by his brother-in-law, which in turn lent the funds, at the same...

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Words and Phrases
included
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract "debt" exists irrespective of demand 99
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) reserve could be claimed on appeal 90
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) bad debt deduction taken as at Dec. 31 in light of information available at April 30, and could be claimed implicitly or on appeal 478

Everett's Truck Stop Ltd. v. The Queen, 93 DTC 965, [1993] 2 CTC 2658 (TCC)

inducement to purchase product for more was includible under s. 12(1)(x), or perhaps s. 9

The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's...

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Words and Phrases
included
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) 96