Words and Phrases - "primarily"

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16 July 2021 Internal T.I. 2020-0872521I7 - CERS - Qualifying property for rental income

significant additional services transform rental income into income from services

Would the owner of a qualifying property that operates a hotel, or other similar business such as a motel or a bed and breakfast, be considered to...

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Words and Phrases
rent income primarily

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

Two taxpayers, dealing at arm's length and carrying on an unincorporated farming business, purchased farm equipment in a qualifying region for use...

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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 172
Tax Topics - General Concepts - Ownership co-owners entitled to pro rata ITCs 63

S4-F15-C1 - Manufacturing and Processing

Application of "primarily"

1.21 ... [T]he term primarily as used in paragraph 5201(a) of the Regulations signifies principally or chiefly and...

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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

The taxpayer (“Gerbro”) was a Canadian investment corporation (owned by a family trust but with an elderly income beneficiary, so that Gerbro...

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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 71
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Minister's statement was false 130
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 115

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

The taxpayer purchased an asphalt plant with the expectation that it would sell up to 40% of the production of the plant to third parties and use...

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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

Hogan J found that dried insects donated by the taxpayer to Laval University were individually appraised and did not "form an unbreakable set,"...

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Words and Phrases
use primarily

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

Although Burger King restaurant were used for "processing" (given that the ordinary meaning of that word did not exclude the preparation of food),...

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Words and Phrases
primarily