Words and Phrases - "undertaking"

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88
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7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 5, 2022-0936301C6 F - Guarantee fee

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
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) one-time fee to subsidiary for mortgaging its property as security for a bank loan to the shareholder would not qualify under s. 20(1)(e.1) 139
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) one-time fee to subsidiary for mortgaging its property as security for a bank loan to the shareholder could qualify under s. 20(1)(e) 175
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) no shareholder benefit where corporation receives a reasonable pledge (or “guarantee”) fee from its shareholder 124

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

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

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

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