Words and Phrases - "payable"
4 June 2024 STEP Roundtable Q. 10, 2024-1010241C6 - Update on trust / estate issues
CRA referred to an unreported 2023 Tax Court of Canada decision (which has not been appealed), which concerned a family trust that realized a...
7 October 2020 APFF Roundtable Q. 17, 2020-0845821C6 F - Part IV tax and trust
A personal trust wholly-owns Opco, which also has a December 31 year end, and has a corporate beneficiary ("Holdco") with a September 30 taxation...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(19) | various applications of proposition that an s. 104(19) designation is not effective until the trust’s year end | 761 |
Tax Topics - Income Tax Act - Section 186 - Subsection 186(2) | s. 104(13), unlike s. 104(19), can apply contemporaneously with a trust dividend distribution, and ss. 186(2) and 251(1)(b) can apply synergistically | 440 |
The Queen v. National Trustco, 98 DTC 6409, [1998] 4 CTC 26 (FCA)
The respondent was liable under s. 224(4) for its failure to respond to s. 224(1) demands (made both before and after the maturity of the GIC in...
Redclay Holdings Ltd. v. The Queen, 96 DTC 1207, [1996] 2 CTC 2347 (TCC)
Part of the consideration given by the taxpayer for the purchase by it of a partnership interest was the assumption by it of a portion of the...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 78 - Subsection 78(1) | 83 |
Collins v. The Queen, 2009 DTC 286, 2009 TCC 56, rev'd supra
The taxpayers owed approximately $2.7 million on mortgage loans including substantial amounts of interest that previously had been agreed to be...
J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC)
A general building contractor in accordance with the terms of its contracts with its subcontractors withheld 10% of the amounts invoiced on a...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 91 | |
Tax Topics - Statutory Interpretation - Certainty | 62 |
The Queen v. Timagami Financial Services Ltd., 82 DTC 6268, [1982] CTC 314 (FCA)
Where the consideration for sale of goodwill is to be paid to the vendor over a series of years, then 1/2 of the amounts so paid are included as...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 44 |
The Queen v. Bank of Nova Scotia, 81 DTC 5115, [1981] CTC 162 (FCA)
The right to claim the tax credit arises in the year that the income in the foreign country is earned. To hold that the amount of the credit is...