Words and Phrases - "in respect of"

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Burton v Commissioner of Taxation, [2019] FCAFC 141

“income” was the full U.S. gain, but FTC to be calculated based on Australian (1/2 recognition) principles

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Words and Phrases
income in respect of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4) credit “in respect of” income only included the taxable ½ of capital gain 183

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141

a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income

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Words and Phrases
in respect of included
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 24 foreign tax credit was not required to be accorded to all the US tax on the gain 345

Commissioner of Inland Revenue v. Lin, [2018] NZCA 38

Chinese tax spared on Chinese CFC income and attributed under CFC regime to New Zealand shareholder was not “in respect of” income derived by that shareholder from China

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Words and Phrases
in respect of

Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65

no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services

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Words and Phrases
for in respect of retainer fee
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation narrow construction of Reg. so as to be intra vires 188
Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 "in respect of" in Regulation read narrowly to conform with "for" in statute 159

4 June 2014 External T.I. 2013-0513761E5 - Meaning of "cost" in determining "equity amount"

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Words and Phrases
cost in respect of

Attorney General of British Columbia v. Canada Trust Co. et al., [1980] 2 S.C.R. 466, [1980] CTC 338

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Words and Phrases
in respect of

The Queen v. Savage, 83 DTC 5409, [1983] CTC 393, [1983] 2 S.C.R. 428

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Words and Phrases
in respect of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) 81
Tax Topics - Statutory Interpretation - Redundancy/reading in words exclusion in specific provision extended to general provision to avoid redundancy 32

Slattery (Trustee of) v. Slattery, 93 DTC 5443, [1993] 3 S.C.R. 430

proceedings by trustee in bankruptcy that would help CRA recover a preferred claim "related to" ITA enforcement

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Words and Phrases
relating to in respect of

Nowegijick v. The Queen, 83 DTC 5041, [1983] CTC 20, [1983] 1 S.C.R. 29

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Words and Phrases
in respect of

Attorney General of British Columbia v. Canada Trust Co. et al., [1980] 2 S.C.R. 466, [1980] CTC 338

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Words and Phrases
in respect of