Words and Phrases - "real property"

a
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b
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c
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d
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e
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f
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g
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i
75
j
2
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32
m
57
n
26
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p
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22 June 2001 Internal T.I. 2001-0078457 F - Décret remise d'impôt revenu gagné au Québec

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (a)
gold royalty was neither TCP nor real property

A non-resident inherited a royalty entitlement to a percentage of the net proceeds of sales from a Quebec gold mine, and then sold the royalty to...

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Words and Phrases
real property

17 May 2021 Internal T.I. 2020-0870041I7 - CERS - Meaning of Qualifying Property

Summary Under
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Property
a property can be bifurcated into a qualifying property and a residence for CERS purposes

Regarding queries as to whether the determination of a property as a qualifying property for Canada emergency rent subsidy (“CERS”) purposes...

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Words and Phrases
real property

Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 6
Art. 6 extends common law meaning of real property

Art. VI of the Australia-U.S. Convention defined real property to include “rights to exploit or to explore for natural resources.” In...

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Words and Phrases
real property
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares private equity fund LP with 5-year holding objective realized share gain on income account 175
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) gains of a NR PE fund from disposals of Australian share investments that were managed in part in Australia were derived from Australia 427
Tax Topics - Treaties - Income Tax Conventions - Article 3 each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise” 234
Tax Topics - Treaties - Income Tax Conventions - Article 13 exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild 420
Tax Topics - General Concepts - Stare Decisis lower court not bound by a point of law that was assumed rather than examined by a higher court 292
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) assessment of partnership was assessment of partners 89
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property 514
Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment shares of Australian mining company were primarily attributable to the processing rather than mining operations 142
Tax Topics - General Concepts - Fair Market Value - Other processing assets of mining company were more valuable than its mining assets 238

1 March 2016 Internal T.I. 2016-0631181I7 - Specified foreign property - mineral rights

Summary Under
Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property
mineral right is real property which is intangible property

After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of...

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Words and Phrases
real property intangible property

Canada v. Larsen, 99 DTC 5757 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property - Paragraph (a)
timber was an incorporeal hereditament in land and, thus, real property

The taxpayer and his three siblings gave a lumber company the right to enter their land to remove timber during a five-month period for...

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Words and Phrases
real property

Notice 269 – Draft GST/HST Memorandum 3.7, "Natural Resources" 15 February 2012

Summary Under
Tax Topics - Excise Tax Act - Section 162 - Subsection 162(2)

Overview of section 162

1. Section 162 deems the following supplies of natural resource property rights not to be supplies for GST/HST...

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Words and Phrases
explore exploit mineral royalty interest gross overriding royalty working interest real property