undertaking

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business
guarantee or pledge fee is from a service and, therefore, is from an undertaking of any kind whatever

An individual, a sole shareholder of a corporation, borrows money in order to earn business or property income. To secure his personal loan, his...

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Words and Phrases
undertaking carry on service

Drumheller v. MNR, 59 DTC 1177, [1959] CTC 275 (Ex Ct) -- summary under Business

Full Title
Drumheller v. MNR, 59 DTC 1177, [1959] CTC 275 (Ex Ct)
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business
lump sum received in lieu of franchise rights was from an undertaking

The taxpayer, who orally agreed with his brother-in-law to jointly seek a franchise to supply a town with natural gas, received $10,000 in lieu of...

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Words and Phrases
undertaking

Lount Corp. v. A.-G. of Canada (1985), 19 DLR (4th) 304 (FCA) -- summary under Subsection 132(6)

Full Title
Lount Corp. v. A.-G. of Canada (1985), 19 DLR (4th) 304 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6)
signal receivers were incidental to whole hotel undertaking

The owners and operators of a Holiday Inn in Winnipeg used television receiving equipment located on the premises to transmit programming to...

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Words and Phrases
undertaking

Baytrust Holdings Ltd. v. IRC, [1971] 1 WLR 1333 (Ch D) -- summary under Subsection 132(6)

Full Title
Baytrust Holdings Ltd. v. IRC, [1971] 1 WLR 1333 (Ch D)
Summary Under
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6)
undertaking denotes business or enterprise

On of the taxpayers ("Nitralloy"), which was a subsidiary of holding company ("Thos. Firth") which carried on a steel manufacturing business...

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Words and Phrases
undertaking

Town of Beauport v. Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. Town of Beauport, [1945] SCR 16 -- summary under Subsection 132(6)

Full Title
Town of Beauport v. Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. Town of Beauport, [1945] S.C.R. 16
Summary Under
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6)
"undertaking" comprised the whole of the company's works

A declaration in the 1895 federal incorporating Act of the appellant that its undertaking was a work for the general advantage of Canada (thereby...

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Words and Phrases
undertaking
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