Open AccessSections 3 and 9 of the Income Tax Act: The Source of Income Concept and the Reasonable Expectation of Profit Rule
Author(s) -
Kerry Harnish
Publication year - 1969
Publication title -
alberta law review
Language(s) - English
Resource type - Journals
eISSN - 1925-8356
pISSN - 0002-4821
DOI - 10.29173/alr1450
Subject(s) - income tax , statute , gross income , economics , profit (economics) , state income tax , international taxation , interpretation (philosophy) , public economics , non profit , law and economics , business , law , microeconomics , tax reform , political science , computer science , programming language , business administration
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.