income

The Queen v. McLaren, 90 DTC 6566, [1990] 2 CTC 429 (FCTD) -- summary under Section 3

Full Title
The Queen v. McLaren, 90 DTC 6566, [1990] 2 CTC 429 (FCTD)
Summary Under
Tax Topics - Income Tax Act - Section 3
"income" must be positive

Before dealing specifically with the interpretation of s. 63(2), MacKay J. found (p. 6572) "that the word 'income', both in its ordinary usage and...

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income

Mark Resources Inc. v. The Queen, 93 DTC 1004, [1993] 2 CTC 2259 (TCC) -- summary under Paragraph 20(1)(c)

Full Title
Mark Resources Inc. v. The Queen, 93 DTC 1004, [1993] 2 CTC 2259 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)
loss utilization was not income-producing purpose/ gross income test

In order to utilize the losses of its U.S. subsidiary, the taxpayer borrowed funds in Canada from an arm's length bank and made a capital...

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Words and Phrases
income

Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62 -- summary under Subparagraph 20(1)(c)(i)

Full Title
Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i)
ancillary purpose of earning (1%-yield) dividend income/allocation of reinvested proceeds 100% to income-producing source

A group of Canadian investors, including the taxpayers, invested in the shares of two Panamanian corporations (collectively, "Justinian") whose...

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Words and Phrases
income

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