Words and Phrases - "rentals"

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1 May 2023 External T.I. 2021-0921101E5 - XXXXXXXXXX

“rentals” not reduced by expenses

Regarding the $10,000 threshold in s. 149(12), CRA indicated that rentals were to be computed without the deduction of related expenses.

Words and Phrases
rentals
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) s. 149(1)(l) NPO can have share capital, but may not so qualify even if it satisfies the CNFPCA 313
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition conversion of share corp to non-share corp would not cause a share disposition if no share cancellation and the rights of the shareholders were not substantively altered 195
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) s. 51 inapplicable to conversion of share corp to non-share corp 191

The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)

lump sum for indefinite right to use property not a royalty

Thurlow, C.J. stated (p. 6275) that "'royalties' ... connotes a payment calculated by reference to the use or to the production or revenue or...

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Words and Phrases
royalties rentals