Words and Phrases - "rent"
CI Burland Properties Limited v MNR, 68 DTC 5220 (SCC)
Municipal taxes which, under the terms of the real property lease between the non-resident taxpayer and a resident tenant, the tenant agreed to...
Extendicare International Inc. v. Minister of Revenue, 2000 CanLII 5653 (Ont CA)
The appellant, which had been leasing computer equipment, notified the lessor that it would no longer be making the agreed monthly payments nor...
29 July 2019 External T.I. 2018-0784701E5 - Rent from real/immovable properties - furnishings
All of the rent generated from a rental unit that was fully-furnished with “furnishings typically … found in a residence” would qualify as...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Rent from Real or Immovable Properties | rent for fully-furnished apartments is all rent | 129 |
Felton v. MNR, 89 DTC 233, [1989] 1 CTC 2329 (TCC)
Since at common law "rent" connates only a payment arising out of a landlord-tenant relationship, home office expenses of the taxpayer (i.e., a...
Shaw v. The Queen, 89 DTC 5194, [1989] 1 CTC 386 (FCTD), aff'd 93 DTC 5213 (FCA)
The taxpayer and her husband had operated a service station in partnership and then transferred pursuant to s. 85(2) the assets of the business...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | 10 | |
| Tax Topics - General Concepts - Substance | 35 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 22 |
Buonincontri v. The Queen, 85 DTC 5277, [1985] 1 CTC 370 (FCTD)
It was held that an 11 suite apartment building had been purchased by a tailor for the purpose of retaining it and renting it, and was accordingly...
MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)
Dumoulin J. stated (p. 1341):
"I incline to believe that a lump-sum payment for rights irrevocably ceded, tantamount to an assignment in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) | 78 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) | 63 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | 60 |
United Geophysical Co. of Canada v. MNR, 61 DTC 1099, [1961] CTC 134 (Ex Ct)
In finding that payments made by the taxpayer to its U.S. parent for the use by it of equipment in its Canadian business represented "rent,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | company's business not carried on as agent for shareholder | 154 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | U.S. equipment rentals not attributable to Canadian services | 137 |
Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104
Lump-sum damages received by the non-resident taxpayer from Canadian residents for the repudiation, prior to the slated operational commencement...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | no onus to rebut a factual assmption re something not within the taxpayer's purview | 170 |
IT-303 "Know-How and Similar Payments to Non-Residents"
Meaning of royalty
7. The Department considers that the words "rent" and "royalty" are used in a broad sense and are not necessarily restricted to...