Words and Phrases - "sale"
Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068
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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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
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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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
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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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 CanLII 25909, 30 BLR (3d) 288; [2003] OJ No 128 (ON SC)
A predecessor of the defendant (“BC Tel”) raised $150 million by transferring receivables to a securitization trust (“RAC”) in...
11 June 2013 STEP Roundtable Q. 9, 2013-0480351C6 - STEP CRA Roundtable Q9 - June 2013
Respecting whether CRA accepted Sommerer, it stated that the decision stood:
for the general proposition that where property is transferred to a...
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...
Home Provisioners (Manitoba) Ltd. v. MNR, 58 DTC 1183 (Ex Ct)
The taxpayer, which sold refrigerators under conditional sales contracts requiring a 10% down payment and the balance payable in 24 monthly...
C.R.I. Environnement Inc. c. La Reine, 2008 DTC 3787, 2007 TCC 206, aff'd 2008 DTC 2471, 2008 FCA 103
The taxpayer, who in consideration for a charge made by it to its customers, sorted, consolidated and reshipped industrial waste produced by them,...