Words and Phrases - "substantially all"

a
89
b
44
c
86
d
56
e
43
f
31
g
20
h
15
i
77
j
2
k
2
l
32
m
57
n
29
o
40
p
82
q
3
r
78
s
95
t
47
u
16
v
10
w
23
y
2

11 October 2013 APFF Roundtable, 2013-0495631C6 F - Actions admissibles de petites entreprises

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation
meaning of "substantially"

Must the 90% level always be attained before the "substantially all" test is satisfied? CRA stated:

When the 90% level is not attained, the CRA...

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Words and Phrases
substantially all

Keefe v. The Queen, 2003 DTC 1526, 2003 TCC 791 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2)

The taxpayer, who was the principal of a family company that was engaged in the supply and installation of commercial floor coverings, used a...

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Words and Phrases
substantially all

Imapro Corp. v. The Queen, 92 DTC 6487 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a)

47.3% of a multi-purpose building which was constructed for a computer graphics corporation was used exclusively by it for scientific research....

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Words and Phrases
substantially all

Benson v. Third Canadian Investment Trust Ltd. (1993), 14 OR (3d.) 493 (Ont. Ct. (G.D.))

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation

Farley J. found that the sale pursuant to a share exchange offer for the direct and indirect shareholding of a closed-end investment company...

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Words and Phrases
substantially all

Hasbro Canada Inc. v. The Queen, 98 DTC 2129 (TCC)

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)

The taxpayer, which was a Canadian manufacturer and distributer of toys in Canada, paid fixed commissions expressed as a percentage of the...

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Words and Phrases
know-how substantially all

Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 118.94

The taxpayer, who received approximately 80% of his income in the form of Public Service Management Insurance Plan disability payments, was found...

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Words and Phrases
substantially all

Reluxicorp Inc. v. The Queen, [2011] GSTC 138, 2011 TCC 336

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Exclusive

The registrant was a hotel company that paid franchise fees to a hotel franchise ("Marriott") in the United States. Marriott's fees were based on...

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Words and Phrases
substantially all