Words and Phrases - "included"
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
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| 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 | 345 |
4 November 2008 External T.I. 2008-0264181E5 - Income recognition and ACB - trust units
Summary Under
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1)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
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Words and Phrases
included| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | 150 |
Delle Donne v. The Queen, 2015 TCC 150
doubtful debt reserve claimed implicitly as at the year end in light of subsequently revealed information
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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 | 87 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | reserve could be claimed on appeal | 82 |
| 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 | 452 |