Words and Phrases - "property"
15 March 2005 Internal T.I. 2004-0108721I7 F - Don d'une licence
In connection with finding that a gift of a non-exclusive software licence was a gift of property, CRA stated:
In Manrell, the Court went on to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | gift of a non-exclusive software licence was a gift of property | 105 |
Aitchison Professional Corporation v. The Queen, 2018 TCC 131
At a time that James Aitchison owed $2.1 million in taxes, he transferred his law practice to a newly-incorporated professional corporation (the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | (foregone) right to negotiate a significant salary was not property | 169 |
Nokes v. Doncaster Amalgamated Collieries Ltd., [1940] A.C. 1014 (HL)
It was held that where a court order was made under the Companies Act 1929, for the amalgamation of two corporations, including an order for the...
The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209
Estey, J. found that the interpretation of the initial version of s. 68 should be interpreted in light of the broad meaning of "property," in s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 68 | 100 | |
| Tax Topics - Statutory Interpretation - Context | 27 |
Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128
A portion of the consideration paid by a purchaser of shares of operating companies in which the taxpayer had been a significant shareholder...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | non-taxable non-compete | 35 |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 35 | |
| Tax Topics - Statutory Interpretation - Legislative History | 57 | |
| Tax Topics - Statutory Interpretation - Other/Conflicting Statutes | foreign statutory context different | 78 |
Medland v. R., 98 DTC 6358, [1999] 4 CTC 293 (FCA)
There was a transfer of property to the taxpayer for purposes of s. 160(1) when her husband, who was the joint mortgagor on a house that at the...
Location Gaétan Lévesque Inc. v. MNR, 91 DTC 1380, [1991] 2 CTC 2795 (TCC)
The taxpayer entered into "leasing contracts" respecting heavy equipment which typically had a term of approximately five years, provided for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Ownership | lessee with purchase option not the beneficial owner | 117 |