Words and Phrases - "may"
STC Steel Technologies Canada, Ltd. v. The King, 2026 TCC 149
“may be deducted” referenced permissive deductions
In finding that s. 261(7)(a)(i), in referring to amounts “that may be deducted” was referencing permissive deductions, Clark J stated (at...
Words and Phrases
may| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(16) | Cdn.$ NCLs of a sub were converted at the spot rate for the most recent completed tax year end when wound up into a USD functional currency parent | 466 |
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(1) - Canadian Tax Results | determination of Canadian tax results included determination of nil | 191 |
| Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(1) | taxation year of sub did not terminate until its dissolution | 71 |
YELLOW POINT LODGE LTD. v. HER MAJESTY THE QUEEN, 2020 FCA 195
requirement to assess where conditions met
A taxpayer, who donated an interest in ecologically sensitive land to two qualified donees in 2008, unsuccessfully argued that the gift was not...
Words and Phrases
may| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(d) - Subparagraph 110.1(1)(d)(iii) | ecological gift was made in the year its ownership was transferred rather than subsequently when the certification conditions under s. 110.1(1)(d)(ii) were met | 310 |
| Tax Topics - Statutory Interpretation - French and English Version | "peut" (may) in French version accorded with a sense of the English version's "shall" | 80 |
8 October 2008 Internal T.I. 2008-0269581I7 - statute-barred refund
request to extend filing deadline or re-appropriate
The corporate taxpayer requested that CRA exercise its discretion under any of ss. 220(2.1), 220(3) and 221.2(1) to refund an overpayment where...
Words and Phrases
may| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 164 - Subsection 164(1.5) | "may" establishes CRA discretion | 128 |
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) | request to extend filing deadline | 70 |
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3) | request to extend filing deadline | 70 |
| Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) | request to re-appropriate | 88 |
Sherman v. The Queen, 2000 DTC 1523 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 127.531"may be deducted" references permissive deduction
In affirming the taxpayer's ability to deduct charitable credits in computing his AMT without also deducting them in computing his liability for...