Words and Phrases - "income from property"

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5 March 2024 External T.I. 2023-0962831E5 - Active business income – Income from solar panels

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business
income from solar array panel might not be income from property, so that there was no SIB

The sole business activity of a Canadian-controlled private corporation (the “Corporation”) was to build a small utility-scale solar array on...

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Words and Phrases
income from property

Hollinger v. M.N.R., 73 D.T.C. 5003, [1972] C.T.C. 592 (FCTD)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 2601 - Subsection 2601(2)
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...

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Words and Phrases
income from property

The Queen v. Canada Southern Railway Co., 86 DTC 6097, [1986] 1 CTC 284 (FCA)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 805
dividends, 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...

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Words and Phrases
income from property
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) 13

Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(5)

Interest income derived by a golf club from the temporary investment of cash surpluses were taxable. Décary J.A. rejected a submission that...

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Words and Phrases
income from property

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 Income
apartment 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...

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Words and Phrases
income from property
Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 54

0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at 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 Business
storage 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...

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Words and Phrases
principal purpose income from property
Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus Minister's pleading of assumptions of law does not relieve taxpayer from entering a case 106