Words and Phrases - "loan"
Meilleur v. The Queen, 2016 TCC 287
Beginning in 2006, the two married taxpayers (Susan and Barry) used their retirement funds and borrowed money to make advances to two real estate...
26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment
After stating that
A loan is generally defined as delivery by one party, and receipt by another party, of a sum of money upon agreement, express...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | advance to employee is current s. 5 income | 239 |
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) | deduction for repayment of transitional advance | 163 |
17 November 1999 T.I. 990126
"[W]here and individual transfers property to a partnership under subsection 97(2) of the Act and receives, in addition to a partnership interest...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) | 112 |
21 March 2001 Internal T.I. 2000-005629
Where landlords agree to pay tenant inducements over a period of twenty years, the taxpayers would account for the amounts payable as "secured...
12 March 1992 External T.I. 5-910839
With respect to an advance made by a Canadian licensor to a U.S. licensor that was repayable only out of royalties to be earned by the licensor,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(vi) | 82 |
5 November 1999 Memorandum 991063
Where a promissory note is issued to pay a dividend, the creditor (in this case, an NRO) will not be considered to have made a loan because no...
29 August 2011 Internal T.I. 2009-0336671I7 - Derivative
Interest rate swap transactions between a controlled foreign affiliate of the taxpayer ("BCo") and a foreign financial institution specializing in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 193 |
Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31
In finding that loans made to the taxpayer by his employer were employment income to him when received, Webb, J. stated (at para. 22):
"in a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 137 |
Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642
The taxpayer was not considered to be engaged in a business of making loans by virtue of the Canadian corporation of which it was a sole...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 95 |
Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra
Noël JA, before rejecting the taxpayer's submission that the post-1993 version of s. 20(1)(p)(ii) contemplated a taxpayer whose ordinary business...
Langhammer v. The Queen, 2001 DTC 45 (TCC)
Before going on to find that losses sustained by the taxpayer after investing in bonds of a condominium development were deductible under s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | occasional loans were money-lending business given that done similarly to a money lender | 259 |
In re Touquoy Gold Mining Co. (1906), 1 E.L.R. 142 (Nova Scotia)
In finding that securities issued by a corporation that were referred to in various corporate documents as "preferred shares" and were evidenced...
Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36
In finding that an agreement, under which in consideration for a payment of $4 million the taxpayer obtained certain rights and privileges to...
Canada Deposit Insurance Corp. v. Canadian Commercial Bank, [1992] 3 S.C.R. 558
A syndicate including the Canadian Deposit Insurance Corportion and six major Canadian banks agreed to provide financial support to Canadian...