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Paragraph 12 (1) (c) of the Income Tax Act (ITA) includes in property income any amount received or receivable by the taxpayer in the
Paragraph 12 (1) (c) of the Income Tax Act ("ITA") includes in property income "any amount received or receivable by the taxpayer in the year". The words "received" and "receivable" are not defined in the ITA or in the Interpretation Act. For the purposes of this statutory provision, which of the following would qualify? (2011 CPAO) (a) Any amount earned or accrued as property income by the taxpayer in the year for the purposes of Canadian GAAP ("ASPE") or IFRS (b) Any amount received or receivable as property income by the taxpayer in the year for the purposes of the common law (c) Both (a) and (b) (d) Neither (a) nor (b). The firm's Taxation partner asks you to verify that the definition of the word "disposed," as it appears in the Income Tax Act, is governed by the definition of the word "disposition" contained in the Income Tax Act. The Taxation partner recalls having read something to the effect that the verb form of a noun does not alter its meaning. Which of the following represents the best source material to consult for verification purposes? (2002 CPAO) (a) Income Tax Act Income Tax Regulations Interpretation Act (c) (c) (d) None of (a), (b), or (c)
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