Words and Phrases - "purpose"
632738 Alberta Ltd. v. The King, 2023 TCC 117
The appellant was assessed under s. 103(1). A representative of the appellant (Mr. Thompson, who wholly-owned it) refused to answer questions...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Solicitor-Client Privilege | company could refuse to not disclose its reasons for engaging in transactions on grounds of privilege | 318 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 96 - Subsection 96(1) | claim of privilege on discovery could have Rule 96(1) consequences | 250 |
Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36
Before finding that the taxpayer’s expenditures for 10-year assignable gaming licences (“GMEs”), which it required in order to be permitted...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract Purchases or Prepayments | 10-year gaming licences required to maintain existing gaming revenues were purchased on capital account | 350 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Concessions and Licences | periodic payments under 30-year government concession were currently deductible | 206 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(34) - Paragraph 13(34)(b) | 10-year gaming licences required to maintain existing gaming revenues were not for goodwill | 245 |
Camp Kahquah Corp. v. The Queen, docket 96-2348-GST-G
The appellant, a registered charity, operated a summer lakeside camp which provided camp experiences for younger and older children, as well as...
Black v. The Queen, 2014 DTC 1046 [at at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275
In 2002, the taxpayer was resident both in Canada and the U.K. for domestic tax purposes, but by virtue of Art. 4, para. 2(a) of the Canada-U.K...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | amendments usually change the Act | 185 |
| Tax Topics - Statutory Interpretation - Other/Conflicting Statutes | presumption against inconsistency | 99 |
| Tax Topics - Treaties - Income Tax Conventions - Article 29 | Treaty residence not domestically applicable | 281 |
The Queen v. Placer Dome Inc., [1997] 1 CTC 72, 96 DTC 6562 (FCA)
After the taxpayer solicited competing bids for the sale of a significant block of shares it held in another public company ("Falconbridge") both...
Newton v. Commissioner of Taxation of the Commonwealth of Australia, [1958] A.C. 450 (PC)
In interpreting the provisions of s. 260 of the Commonwealth Income Tax and Social Services Contribution Assessment Act, 1936-1951 (Australia),...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 260 - Subsection 260(1) - Securities Lending Arrangement | "arrangement" | 130 |
1207192 Ontario Limited v. Canada, 2012 DTC 5157 [at at 7396], 2012 FCA 259, aff'g 2011 DTC 1301 [at 1686], 2011 TCC 383
In the course of applying s. 245 to deny the recognition by the taxpayer of a capital loss, the Court considered and rejected the argument of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | capital loss from value shift did not reflect economic loss; purpose objectively determined | 451 |