Words and Phrases - "real property"
17 May 2021 Internal T.I. 2020-0870041I7 - CERS - Meaning of Qualifying Property
Summary UnderTax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Property
a property can be bifurcated into a qualifying property and a residence for CERS purposes
Regarding queries as to whether the determination of a property as a qualifying property for Canada emergency rent subsidy (“CERS”) purposes...
Words and Phrasesreal property
Resource Capital Fund IV LP v Commissioner of Taxation,  FCA 41 (Federal Court of Australia), rev'd on various grounds  FCAFC 51
Art. 6 extends common law meaning of real property
Art. VI of the Australia-U.S. Convention defined real property to include “rights to exploit or to explore for natural resources.” In...
Words and Phrasesreal property
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|Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares||private equity fund LP with 5-year holding objective realized share gain on income account||175|
|Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii)||gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia||427|
|Tax Topics - Treaties - Income Tax Conventions - Article 3||each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise”||234|
|Tax Topics - Treaties - Income Tax Conventions - Article 13||exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild||420|
|Tax Topics - General Concepts - Stare Decisis||lower court not bound by a point of law that was assumed rather than examined by a higher court||292|
|Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)||assessment of partnership was assessment of partners||89|
|Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d)||shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property||514|
|Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment||shares of Australian mining company were primarily attributable to the processing rather than mining operations||142|
|Tax Topics - General Concepts - Fair Market Value - Other||processing assets of mining company were more valuable than its mining assets||238|
1 March 2016 Internal T.I. 2016-0631181I7 - Specified foreign property - mineral rights
Summary UnderTax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property
mineral right is real property which is intangible property
After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of...
Words and Phrasesreal property intangible property