Words and Phrases - "lease"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
73
s
85
t
44
u
14
v
8
w
20
y
2
“
1

J.D. Irving Limited v. Agence du revenu du Québec, 2020 QCCQ 2423, aff'd 2022 QCCA 241

Summary Under
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17)
property serviced by the user was not a leasing property

The taxpayer ("JDI") and another pulp and paper company in the Irving group (“IPPL”) participated in transactions to effectively transfer...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
lease
Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency Stubart recognized that business operations can be carried on by an affiliated agent 231
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) loss consolidation transaction entailing circular transfers of depreciable property confirmed 90

P-062 “Distinction Between Lease, License and Similar Arrangements” 25 May 1993

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Residential Complex

Lease confers exclusive possession

In the common law provinces, it has generally been determined that a lease normally confers exclusive...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
lease licence

24 December 2015 Internal T.I. 2014-0560831I7 - International shipping

Summary Under
Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c)
commercial management is still sufficient/charterparties are “leases”

The Taxpayer is a non-resident corporation that carries on business in many countries, including Canada. The activities of the non-resident...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
lease
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Shipping lease includes time charter 67

Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17)
no "lease" where failure to provide exclusive possession

A British corporation ("WBDL") entered into a distribution agreement with a California corporation ("WBI") pursuant to which WBI was granted the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
lease

Canadian Acceptance Corp. Ltd. v. Regent Park Butcher Shop Ltd. (1969), 67 WWR 297 (Man. C.A.)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17)
irrevocable chattel lease was lease

Dickson J.A. found that the hiring of a cash register was a chattel lease notwithstanding a clause that provided that the lease was irrevocable...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
lease