Brown v. The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA) -- summary under Paragraph 1102(1)(c)

By services, 28 November, 2015

The word "income" in Regulation 1102(1)(c) means an amount that would be subject to tax, not net income. That requirement was satisfied with respect to the acquisition of software game "engines" by a partnership notwithstanding that the partners may have invested to save tax. They reasonably expected to make a profit from the programs.

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Topic
Income Tax Regulations - s. 1102(1)(c)
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Node
Drupal 7 entity ID
339881
Extra import data
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