Words and Phrases - "included"

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28
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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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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 345

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

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Words and Phrases
included

Quigley v. The Queen, 96 DTC 1057 (TCC)

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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

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Words and Phrases
included

Langdon v. Canada, 2000 DTC 6203 (FCA)

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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

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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