Cases
R. v. Loosdrepht, 2009 DTC 6088 (BC Prov. Ct.)
Before going on to find that the individual taxpayer had committed tax evasion by filing nil returns and taking the position that he was not a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(a) | 24 |
Doyle v. MNR, 89 DTC 5483 (FCTD)
A reference in s. 225.1(5) to a taxpayer "should be interpreted as allowing an agent to sign on behalf of a taxpayer providing the agency is well...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | 119 | |
| Tax Topics - Income Tax Act - Section 221 - Subsection 221(1) - Paragraph 221(1)(f) | 49 | |
| Tax Topics - Income Tax Act - Section 225.1 - Subsection 225.1(5) | 50 |
The Queen v. Merali, 88 DTC 6173, [1988] 1 CTC 320 (FCA)
"[B]oth residents and non-residents who derive income from Canadian sources are included, by definition, in the term 'taxpayer'." [C.R.: 248(1) -...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | 44 | |
| Tax Topics - Income Tax Act - Section 216 - Subsection 216(1) | 106 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 60 |
Oceanspan Carriers Ltd. v. The Queen, 87 DTC 5102, [1987] 1 CTC 210, 87 DTC 5102 (FCA)
"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,...
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|---|---|---|
| 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 |
Gordon v. The Queen, 86 DTC 6426, [1986] 2 CTC 280 (FCTD), aff'd 89 DTC 5481 (FCA)
It was found respecting some losses from a partnership engaged in the breeding and racing of horses that s. 31(1) applies at the level of the...
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| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 143 |
Lea-Don Canada Limited v. Minister of National Revenue, 70 DTC 6271, [1971] S.C.R. 95
A Canadian subsidiary ("Nassau") of a Bermudan company that did not carry on business in Canada was leasing an aircraft to the appellant, which...
See Also
King George Hotels Ltd. v. MNR, 68 DTC 635 (TAB)
An incorporated charitable foundation was found to be a "taxpayer" notwithstanding that it was not taxable under s. 62(1)(f) of the pre-1972 Act.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b) | 59 |
Administrative Policy
23 July 1996 External T.I. 5-960222
A non-resident trust that does not carry on business in Canada, does not hold taxable Canadian property and is not subject to s. 94 of the Act...
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| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) | 73 |
18 January 1993 External T.I. 5-921718
A loan by a non-resident individual to a Canadian partnership secured by a second mortgage on a building owned by the partnership, that provided...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(4) | 127 |
23 September 1991 Memorandum (Tax Window, No. 8, p. 22, ¶1429)
In determining the number of shares under the 25% test in s. 115(1)(b)(iv), options held by the non-resident person or non-arm's length person are...
IT-176R2 "Taxable Canadian Property - Interest in and Options on Real Property and Shares"
84 C.R. - Q.16
"taxpayer" in s. 20(1)(j) is considered to include a partnership where a loan previously has been included in the partnership's income.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | 24 |