Words and Phrases - "reasonable"
Pinnacle International Realty Group II Inc. v. The King, 2023 TCC 161
partnership profit reallocated under s. 103(1) based on relative contribution
The taxpayer and another wholly-owned subsidiary (“Taylor”) of the same corporation (“PIRG”) were the 5% and 95% partners, respectively,...
Words and Phrases
reasonableConnolly v. Canada (National Revenue), 2019 FCA 161
CRA internal guidelines on waiving the RRSP over-contribution tax were inherently unreasonable
The taxpayer did not file income tax returns for the 1988 to 2003 taxation years on the basis that as he owed no tax, this was unnecessary. Thus,...
Words and Phrases
reasonableSun Life Assurance Company of Canada v. The Queen, 2015 TCC 37
holding of vacant office space by a GST-exempt business for potential future taxable rentals qualified for ITC purposes as commercial activity/first order intended supply of vancant space was for rentals
The appellant ("Sun Life"), whose principal business was the sale of financial products, subleased space in its various office buildings to...
Words and Phrases
reasonableLocations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) | vacant office space was used for future taxable supplies | 89 |