Words and Phrases - "intention"

a
88
b
44
c
80
d
54
e
38
f
31
g
20
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
77
s
90
t
47
u
16
v
9
w
23
y
2

Backman v. Canada, 2001 DTC 5149, 2001 SCC 10, [2001] 1 S.C.R. 367

Summary Under
Tax Topics - General Concepts - Purpose/Intention
motivation v. purpose

Before finding that the taxpayers had not entered into an arrangement with the requisite intention to be partners, the Court stated (at para. 22) that "motivation is that which stimulates a person to act, and intention is a person's objective or purpose in acting. This Court has repeatedly held that a tax motivation does not derogate from the validity of transactions for tax purposes ...".

Words and Phrases
intention motivation
Locations of other summaries Wordcount
Tax Topics - General Concepts - Tax Avoidance 87
Tax Topics - Income Tax Act - Section 96 essential Canadian elements of partnership not present as only momentarily "partners" in common 298
Tax Topics - Statutory Interpretation - Provincial Law foreign "partnership" must have the attributes of a Cdn partnership 153