Words and Phrases - "income"

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Burton v Commissioner of Taxation, [2019] FCAFC 141

“income” was the full U.S. gain, but FTC to be calculated based on Australian (1/2 recognition) principles

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Words and Phrases
income in respect of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4) credit “in respect of” income only included the taxable ½ of capital gain 183

29 May 2018 STEP Roundtable Q. 5, 2018-0743961C6 - Tax on Split Income

“income” means “revenue,” and incidental property revenue is assimilated to services revenue

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Words and Phrases
income

26 April 2017 IFA Roundtable Q. 7, 2017-0691221C6 - Clause 95(2)(a)(ii)(D)

“income” includes “loss,” but s. 95(2)(a)(ii)(D)(IV)2 inapplicable re an LLC interest that is sold before year end

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Words and Phrases
income

13 January 2014 External T.I. 2013-0512581E5 - Sale of shares of Brazilian corporation

"income" includes taxable capital gains

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Words and Phrases
income

454538 Ontario Ltd. v. MNR, 93 DTC 427 (TCC)

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Mark Resources Inc. v. The Queen, 93 DTC 1004 (TCC)

loss utilization was not income-producing purpose/ gross income test

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Words and Phrases
income
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 98

Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62

ancillary purpose of earning (1%-yield) dividend income/allocation of reinvested proceeds 100% to income-producing source

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Words and Phrases
income
Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention objective and subjective manifestations of purpose 98
Tax Topics - General Concepts - Tax Avoidance right to structure for tax avoidance 121
Tax Topics - Statutory Interpretation - Certainty 97