Words and Phrases - "lease"

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

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

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

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.)

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.)

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