Words and Phrases - "primarily"

66
29
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12
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52
1
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19
38
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20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole

test is of intention on acquisition to use over 50%, during months of likely use during the equipment’s lifetime, on farm in the region
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Words and Phrases
primarily
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(27) no ITC reversal if unanticipated transfer of equipment to a farm outside the region 155
Tax Topics - General Concepts - Ownership co-owners entitled to pro rata ITCs 54

S4-F15-C1 - Manufacturing and Processing

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Words and Phrases
primarily

Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197

offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply
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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus no taxpayer burden to displace assumptions of mixed fact and law 65
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Minister's statement was false 120
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) expert's report did not include all the underlying data 109

Will Kare Paving & Contracting Ltd. v. The Queen, 98 DTC 6203 (FCA)

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Words and Phrases
primarily

Plamondon v. The Queen, 2011 DTC 1137 [at 746], 2011 TCC 47 (Informal Procedure)

each donated dried insect was separate property
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Words and Phrases
use primarily

Burger King Restaurants of Canada Inc. v. Canada, 2000 DTC 6061 (FCA)

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Words and Phrases
primarily