in-print-bilateral-benefits-0409-en

Usguidanceinthisareaismorehelpfulseveralprivate

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Unformatted text preview: any 32 at the seminar, supra note 17, the Cra suggested that practitioners should refer to Canadian case law, such as Atlas Industries Ltd. v. MNR, 86 DTC 1756 (TCC), and McCutcheon Farms Limited v. The Queen, 91 DTC 5047 (FCTD), in interpreting the definitions of “incidental” and “pertaining to.” The Cra suggested that there must be a financial relationship between the property and the active business before the income from the property may be considered to be incidental to the active business. 33 united states, Department of the Treasury, Technical Explanation accompanying the united states Model income Tax Convention of November 15, 2006, at 70. 100 n c anadian tax journal / revue fiscale canadienne ( 2009) vol. 5 7 , n o 1 and used in conjunction with the sale of tour packages that include air travel and lodging at these hotels are complementary businesses. The international airline business and the hotel business are part of the same overall industry (travel), and the links betwe...
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