Words and Phrases - "liability"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Barejo Holdings ULC v. Canada, 2020 FCA 47

Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) - Paragraph 94.1(1)(a)
the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity

An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...

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Words and Phrases
debt liability
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Consistency presumption of consistent expression is not absolute 252
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract 3 tests for what constituted debt under s. 94.1(1)(a) 300

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:

Summary Under
Tax Topics - Income Tax Act - Section 222 - Subsection 222(1) - Tax debt

"Liability" v. "debt" (pp. 716-717)

The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...

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Words and Phrases
liability debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 39