substantially all

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation
90% is generally a safe harbour, and in a particular context CRA may accept lower than 90%

Must the 90% level always be attained before the "substantially all" test is satisfied? CRA stated:

According to the jurisprudence, the...

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substantially all

Keefe v. The Queen, 2003 DTC 1526, 2003 TCC 791 (Informal Procedure) -- summary under Subsection 6(2)

Full Title
Keefe v. The Queen, 2003 DTC 1526, 2003 TCC 791 (Informal Procedure)
Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2)

The taxpayer, who was the principal of a family company that was engaged in the supply and installation of commercial floor coverings, used a...

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Words and Phrases
substantially all

Imapro Corp. v. The Queen, 92 DTC 6487, [1992] 2 CTC 298 (FCTD) -- summary under Paragraph 37(8)(a)

Full Title
Imapro Corp. v. The Queen, 92 DTC 6487, [1992] 2 CTC 298 (FCTD)
Summary Under
Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a)

47.3% of a multi-purpose building which was constructed for a computer graphics corporation was used exclusively by it for scientific research....

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Words and Phrases
substantially all

Benson v. Third Canadian Investment Trust Ltd. (1993), 14 OR (3d.) 493 (Ont. Ct. (G.D.)) -- summary under Small Business Corporation

Full Title
Benson v. Third Canadian Investment Trust Ltd. (1993), 14 OR (3d.) 493 (Ont. Ct. (G.D.))
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation

Farley J. found that the sale pursuant to a share exchange offer for the direct and indirect shareholding of a closed-end investment company...

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Words and Phrases
substantially all

Hasbro Canada Inc. v. The Queen, 98 DTC 2129, [1999] 1 CTC 2512 (TCC) -- summary under Paragraph 212(1)(d)

Full Title
Hasbro Canada Inc. v. The Queen, 98 DTC 2129, [1999] 1 CTC 2512 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)

The taxpayer, which was a Canadian manufacturer and distributer of toys in Canada, paid fixed commissions expressed as a percentage of the...

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Words and Phrases
know-how
substantially all

Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure) -- summary under Section 118.94

Full Title
Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure)
Summary Under
Tax Topics - Income Tax Act - Section 118.94

The taxpayer, who received approximately 80% of his income in the form of Public Service Management Insurance Plan disability payments, was found...

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Words and Phrases
substantially all

Reluxicorp Inc. v. The Queen, [2011] GSTC 138, 2011 TCC 336 -- summary under Exclusive

Full Title
Reluxicorp Inc. v. The Queen, [2011] GSTC 138, 2011 TCC 336
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Exclusive
75% was not substantially all

The registrant was a hotel company that paid franchise fees to a hotel franchise ("Marriott") in the United States. Marriott's fees were based on...

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substantially all

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