Words and Phrases - "sale"

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Pharma Coréalis Inc. v. Agence du revenu du Québec, 2023 QCCQ 156

putting pharmaceutical companies’ drugs into capsules for clinical tests qualified as manufacturing for sale

The taxpayer (Coréalis) which, in addition to performing R&D services, entered into “service agreements” with pharmaceutical companies (the...

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Words and Phrases
sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) - Subparagraph (c)(i) putting drug companies' active ingredients into capsule form for clinical testing qualified as manufacturing for sale 289

Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068

consideration for a transfer of waste included the assumption of environmental responsibility

The taxpayer received organic sludge from suppliers in the agri-food industry, and was paid by them for taking over the sludge, which it then...

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Words and Phrases
consideration sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits a taxpayer made sales of partially processed waste when it paid other processors to complete its processing 354

12 November 2019 External T.I. 2019-0822161E5 F - T5008 Statement of Securities Transactions

a contribution of shares to a TFSA is not a “sale” for Reg. 230 purposes

During the 2019 calendar year, Mr. X withdrew the minimum amount (as defined in subsection 146.3(1)) from his RRIF ($5,000 – so that a T4RIF...

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Words and Phrases
sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 230 - Subsection 230(2) transfer of listed shares from taxable brokerage account to individual’s TFSA did not generate T5008 reporting requirement 65

Stark International Inc. v. The Queen, 2019 TCC 248

oil-processing equipment was for sale even though initial use was to process customer's oil

The taxpayer (“Stark”) used three newly-constructed transformer maintenance trailers (which were 50-foot trailers (“TMT 3, TMT 4 and TMT...

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Words and Phrases
sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) a use test could be applied by looking beyond the property’s immediate intended use 235

Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC)

true sale to securitization trust rather than secured loan

A predecessor of the defendant (“BC Tel”) raised $150 million by transferring receivables to a securitization trust (“RAC”) in...

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Words and Phrases
sale

11 June 2013 STEP Roundtable Q. 9, 2013-0480351C6 - STEP CRA Roundtable Q9 - June 2013

meaning of sale in Sommerer

Respecting whether CRA accepted Sommerer, it stated that the decision stood:

for the general proposition that where property is transferred to a...

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Words and Phrases
sale

Renaud v. The Queen, 2010 DTC 1094 [at 2994], 2010 2010 TCC 76

The taxpayer made an eligible relocation to a residence in another town. Rather than sell his old residence, he rented it, which effected a...

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Words and Phrases
sale

Home Provisioners (Manitoba) Ltd. v. MNR, 58 DTC 1183, [1958] CTC 334 (Ex Ct)

The taxpayer, which sold refrigerators under conditional sales contracts requiring a 10% down payment and the balance payable in 24 monthly...

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Words and Phrases
sale

C.R.I. Environnement Inc. c. La Reine, 2008 DTC 3787, 2007 TCC 206, aff'd 2008 DTC 2471, 2008 FCA 103

transfer of waste material for no consideration received back other than assumption of environmental obligation was not a sale

The taxpayer, who in consideration for a charge made by it to its customers, sorted, consolidated and reshipped industrial waste produced by them,...

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Words and Phrases
sale