Words and Phrases - "payable"

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4 June 2024 STEP Roundtable Q. 10, 2024-1010241C6 - Update on trust / estate issues

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b)
an amount paid by a trust to a beneficiary is not deductible under s. 104(6) if it was not payable under the trust deed

CRA referred to an unreported 2023 Tax Court of Canada decision (which has not been appealed), which concerned a family trust that realized a...

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Words and Phrases
payable

7 October 2020 APFF Roundtable Q. 17, 2020-0845821C6 F - Part IV tax and trust

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24)
under the ordinary meaning of payable, an amount is payable at a time if it is paid then

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...

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Words and Phrases
payable
Locations of other summaries Wordcount
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)

Summary Under
Tax Topics - Income Tax Act - Section 224 - Subsection 224(1)
liability of trustee for collapsed RRSP amounts not paid pursuant to requirement was an amount for which it was "responsible at law"

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...

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Words and Phrases
liable payable

Collins v. The Queen, 2009 DTC 286, 2009 TCC 56, rev'd supra

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)

The taxpayers owed approximately $2.7 million on mortgage loans including substantial amounts of interest that previously had been agreed to be...

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Words and Phrases
payable

Redclay Holdings Ltd. v. The Queen, 96 DTC 1207, [1996] 2 CTC 2347 (TCC)

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)
interest not payable if contingent cash flow

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...

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Words and Phrases
payable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 78 - Subsection 78(1) 83

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)

Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e)

A general building contractor in accordance with the terms of its contracts with its subcontractors withheld 10% of the amounts invoiced on a...

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Words and Phrases
payable

The Queen v. Timagami Financial Services Ltd., 82 DTC 6268, [1982] CTC 314 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital

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...

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Words and Phrases
payable

The Queen v. Bank of Nova Scotia, 81 DTC 5115, [1981] CTC 162 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(2)
foreign tax translated at FX rate when foreign income earned

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...

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Words and Phrases
payable