Words and Phrases - "lease"

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

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...

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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...

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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...

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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...

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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...

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Words and Phrases
lease