Words and Phrases - "money-lending business"
Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra
Summary UnderTax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii)
a taxpayer with a warehousing business potentially could have a lending business under a cash pooling arrangement
Noël JA, before rejecting the taxpayer's submission that the post-1993 version of s. 20(1)(p)(ii) contemplated a taxpayer whose ordinary business...
Words and Phrasesloan money-lending business
A.P. Toldo Holding Corporation v. The Queen, 2014 DTC 1042 [at 2787], 2013 TCC 416
Summary UnderTax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures
no retained earnings or stated capital
The taxpayer was a holding company for various direct and indirect subsidiaries which carried on an operating business. To resolve a shareholder...
Words and Phrasesmoney-lending business
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|Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)||no retained earnings or stated capital||209|