Words and Phrases - "income from property"
Hollinger v. M.N.R., 73 D.T.C. 5003, [1972] C.T.C. 592 (FCTD)
share of profits from foreign bottling partnership was business, not property, income
The taxpayer was an individual resident in Quebec who took the position that her share of income earned by a New Jersey partnership engaged in...
Words and Phrases
income from propertyThe Queen v. Canada Southern Railway Co., 86 DTC 6097, [1986] 1 CTC 284 (FCA)
Summary Under
Tax Topics - Income Tax Regulations - Regulation 805dividends, being themselves income from property, were not exempted notwithstanding their commercial connection to the recipinent's business
Dividends that the taxpayer paid to a US shareholder (“Penn Central”) were, as an historical matter, in lieu of amounts that Penn Central...
Words and Phrases
income from propertyLocations of other summaries | Wordcount | |
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Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | 13 |
Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)
Interest income derived by a golf club from the temporary investment of cash surpluses were taxable. Décary J.A. rejected a submission that...
Words and Phrases
income from propertyLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 47 |
Burri v. The Queen, 85 DTC 5287, [1985] 2 CTC 42 (FCTD)
Summary Under
Tax Topics - Income Tax Act - Section 129 - Subsection 129(4) - Canadian Investment Incomeapartment rentals were not from an active business
Net rental income which a company derived from an apartment building in its 1978 and 1979 taxation years (managed by an affiliated property...
Words and Phrases
income from propertyLocations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Evidence | 54 |
0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231
Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Businessstorage charges were property income, cf. hotel revenue
The taxpayer, which had two employees including its shareholder, carried on a storage unit rental business.
Before referring to the "principal...
Locations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Onus | Minister's pleading of assumptions of law does not relieve taxpayer from entering a case | 106 |