Words and Phrases - "purpose"

82
43
75
50
36
31
17
13
70
2
2
30
51
25
38
79
2
73
85
44
14
8
20
2
1

632738 Alberta Ltd. v. The King, 2023 TCC 117

the taxpayer’s sole shareholder could field the queries as to the purpose of the taxpayer, which might equate to the reason for the transaction

The appellant was assessed under s. 103(1). A representative of the appellant (Mr. Thompson, who wholly-owned it) refused to answer questions...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose reason
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

purpose distinguished from motive

Before finding that the taxpayer’s expenditures for 10-year assignable gaming licences (“GMEs”), which it required in order to be permitted...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose motive
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose

Black v. The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275

Treaty residence not domestically applicable

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose
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

After the taxpayer solicited competing bids for the sale of a significant block of shares it held in another public company ("Falconbridge") both...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose

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),...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
purpose