Words and Phrases - "month"
9 October 2025 APFF Roundtable, Q.13
February 28 to March 31 is one month
A corporation, whose deadline for filing an s. 85(1) election was the last day of February (February 28), did not file the election until March 28...
Words and Phrases
month| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(8) | there is only one penalty month if an election due on February 28 was filed on or before March 31 of the following month | 289 |
26 March 1986 Income Tax Severed Letter RCT 85-243
passage of 1 month is from day X of one month to day X-1 of following month, so that there is a part month on day X of that following month
Regarding the computation in ss. 85(8), 93(6), 96(6) of the period of each month or part of a month commencing on the date the election was...
Words and Phrases
month| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(1) - Paragraph 162(1)(b) | not passage of a complete month where return required to be filed on Feb 28 is filed on March 29 | 721 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 28 | computation of month from is from day X of one month to day X-1 of following month | 178 |
21 November 2023 Internal T.I. 2021-0880101I7 - Article 5(3)(b) of the Canada-Mexico Treaty
the “six months” test in Art. 5(3)(b) of the Mexico Treaty should be day-counted (more than 183 days)
Art. 5(3)(b) of the Mexico-Canada Convention provides that a “permanent establishment” includes:
(b) the furnishing of services, including...
Words and Phrases
month23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty
the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time
Art. V(4) of the Canada-U.S. Treaty provides that a permanent establishment exists in a Contracting State if the use of an installation or...
MNR v. Kayelle Management (Yukon) Inc., 94 DTC 6116, [1994] 1 CTC 271 (FCA)
The taxpayer, which was a Canadian-controlled private corporation, had a fiscal year-end of February 1, 1990. It was not required to pay the final...
Words and Phrases
month| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 28 | 46 |