Sections 3 and 9 of the Income Tax Act: The Source of Income Concept and the Reasonable Expectation of Profit Rule

Authors

  • Kerry Harnish

DOI:

https://doi.org/10.29173/alr1450

Abstract

This article explores the development of several concepts important to the interpretation and application of income tax law in Canada. Specifically, the author traces the evolution of the source of income concept from its conception in the early income tax statutes to its modern usage. The author goes on to describe how this concept underlies the application of ss. 3 and 9 of the present Income Tax Act, and the "reasonable expectation of profit" rule.

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