Words and Phrases - "taxpayer"
Marino v. The Queen, 2020 TCC 50 (Informal Procedure), aff'd 2022 FCA 115
an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit
An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating...
Words and Phrases
taxpayer| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(b) | tuition paid prior to becoming subject to tax under Part I was not to be recognized under s. 118.5(1)(b) | 455 |
| Tax Topics - Income Tax Act - Section 250.1 - Paragraph 250.1(a) | s. 250.1 applies only to persons who would not be taxpayers under Oceanspan | 276 |
Byron Beswick, "Transfer Pricing and Transactions Between Foreign Entities", Canadian Tax Journal, (2019) 67:1, 187-208
Overview (p. 188)
[A] textual, contextual, and purposive analysis of section 247 and other Canadian transfer-pricing provisions, in particular...
Words and Phrases
taxpayerOceanspan Carriers Ltd. v. The Queen, 87 DTC 5102, [1987] 1 CTC 210 (FCA)
"taxpayer" refers to a person who may become liable to tax
"Taxpayer" "refers to resident individuals or corporations who may be liable to pay tax at some time whether or not they are, at any given time,...
Words and Phrases
taxpayer| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | 62 | |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 77 |