Words and Phrases - "liability"

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Barejo Holdings ULC v. Canada, 2020 FCA 47

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:

"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