Words and Phrases - "included"
13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits
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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|---|---|---|
| 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
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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| 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 |
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,...
4 November 2008 External T.I. 2008-0264181E5 - Income recognition and ACB - trust units
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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|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | 154 |
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...
Delle Donne v. The Queen, 2015 TCC 150
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...
| 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)
The assumption by another corporation ("Polar Oils") of the obligation of the taxpayer to pay $119,658 in consideration for the taxpayer's...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) | 96 |