Effective Date

Commentary

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Cases

Nussey Estate v. The Queen, 2001 DTC 5240, 2001 FCA 99

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Stone's Jewellery Ltd. v. Arora, [2000] GSTC 168 (Alta. Ct. Q.B.)

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Sussex Square Apartments Ltd. v. The Queen, [1999] 2 CTC 2143 (TTC), aff'd [2000] 4 CTC 203 (FCA)

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Tax Topics - General Concepts - Stare Decisis 34

Barnabe Estate v. The Queen, 99 DTC 5387 (FCA)

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The Queen v. Larsson, 97 DTC 5425, docket A- 623-96 (FCA)

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Dale v. The Queen, 97 DTC 5252, Docket: A-15-94 (FCA)

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Greenway v. The Queen, 96 DTC 6529, Docket: A-392-91 (FCA)

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Kettle River Sawmills Ltd. v. The Queen, 92 DTC 6525 (FCTD)

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R. v. Hutton, [1990] 2 CTC 258 (Alta. C.A.)

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Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)

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Bouchard v. The Queen, 83 DTC 5193, [1983] CTC 173 (FCTD)

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Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

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Perini Estate v. The Queen, 82 DTC 6080, [1982] CTC 74 (FCA)

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Kingsdale Securities Co. Ltd. v. The Queen, 74 DTC 6674, [1975] CTC 10 (FCA)

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Howard v. The Queen, 74 DTC 6607, [1974] CTC 857 (FCTD)

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Tax Topics - Income Tax Act - 41-60 - Section 60 - Paragraph 60(c) 81

Nelson v. The Queen, 74 DTC 6266, [1974] CTC 360 (FCA)

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Tax Topics - Income Tax Act - 41-60 - Section 56 - Subsection 56(2) 169

Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

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Rose v. MNR, 73 DTC 5083, [1973] CTC 74 (FCA)

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MNR v. Lechter, 66 DTC 5300, [1966] CTC 434, [1966] S.C.R. 655

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Tax Topics - Income Tax Act - 1-20 - Section 9 - Timing 90

Falconer v. MNR, 62 DTC 1247, [1962] CTC 426, [1962] S.C.R. 664

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See Also

Fiducie Claude Deragon v. The Queen, 2015 CCI 294

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Tax Topics - Income Tax Act - 41-60 - Section 54 - Proceeds of Disposition - Paragraph (a) sales proceeds reduced by subsequent price adjustment clause but included conditional sales proceeds 474
Tax Topics - Income Tax Act - 1-20 - Section 12 - Subsection 12(1) - (e)-(x) - Paragraph 12(1)(g) reverse earnout amounts included in proceeds 238

Charania v. The Queen, 2015 DTC 1103 [at 614], 2015 TCC 80

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Tax Topics - Income Tax Act - 1-20 - Section 15 - Subsection 15(1) no shareholder benefit from erroneous property valuation 304

Murphy Estate v. The Queen, 2015 TCC 8

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Words and Phrases
disclaimer
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Tax Topics - Income Tax Act - 141-160 - Section 146 - Subsection 146(8.8) consent order for settlement of estate litigation did not have retroactive effect 195

Al-Hossain v The Queen, 2014 TCC 379

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Tax Topics - Excise Tax Act - 224-341 - Section 254 - Subsection 254(2) co-owner was not occupant and bare trust declaration was too late 260
Tax Topics - Income Tax Act - 101-120 - Section 104 - Subsection 104(1) bare trust declaration was too late 126

James v. The Queen, 2013 DTC 1135 [at 705], 2013 TCC 164

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Tax Topics - Income Tax Act - 41-60 - Section 56.1 - Subsection 56.1(4) - Support Amount retroactive court orders 97

Twomey v. The Queen, 2012 DTC 1255 [at 3739], 2012 TCC 310

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Tax Topics - Income Tax Act - 101-120 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share records rectified to reflect 24-mo. hold for shares 270

Sommerer v. The Queen, 2011 DTC 1162 [at 845], 2011 TCC 212, aff'd 2012 FCA 207

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Gestion Forêt-Dale Inc. v. The Queen, 2009 DTC 1378, 2009 TCC 255

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Gagnon v. The Queen, 2008 DTC 3111, 2006 TCC 194

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Lloyd v. The Queen, 2002 DTC 1493, Docket: 2000-1146-IT-G (TCC)

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Fallis v. The Queen, 2002 DTC 1242, Docket: 2000-383-IT-G (TCC)

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McAnulty v. The Queen, 2001 DTC 942, Docket: 2000-420-IT-G (TCC)

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Glassford v. The Queen, 2000 DTC 2531, Docket: 97-2826-IT-G (TCC)

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Horkoff v. The Queen, 97 DTC 621 (TCC)

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Tax Topics - Income Tax Act - 81-100 - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) back-dated dividend 65

Leung v. MNR, 92 DTC 1090 (TCC)

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Tax Topics - General Concepts - Fair Market Value - Shares 175

Voukelatos v. MNR, 92 DTC 1076 (TCC)

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Seaman v. MNR, 90 DTC 1909 (TCC)

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May Estate v. MNR, 89 DTC 534 (TCC)

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Pellizzari v. MNR, 87 DTC 56 (TCC)

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Robert Bédard Auto Ltée. v. MNR, 85 DTC 643 (TCC)

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Spence v IRC (1941), 24 TC 311 (Ct of Sess (1st Div'n))

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Waddington v. O'Callaghan (1931), 16 TC 187 (KBD)

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Administrative Policy

16 June 2016 T.I. 2015-0623031E5 F - Application of paragraph 7(1)(b)

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Tax Topics - Income Tax Act - 1-20 - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) contingent amount included under s. 7(1)(b), cannot subsequently be excluded 229

9 October 2015 APFF Roundtable Q. 10, 2015-0595671C6 F - Question 10 - Table Ronde APFF 2015

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Tax Topics - Income Tax Act - 1-20 - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose generally whould be reimbursement for expenses incujrred for affiliate 220

2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover

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Tax Topics - Income Tax Act - 201-220 - Section 215 - Subsection 215(6) Spinco taking responsibility for Part XIII remittance obligation of Parent 206
Tax Topics - Income Tax Act - 41-60 - Section 52 - Subsection 52(2) taxable dividend spin-off of thinly capitalized sub 249

29 October 2013 T.I. 2013-0507881E5 - Price adjustment clause

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Tax Topics - Income Tax Act - 81-100 - Section 84 - Subsection 84(3) price adjustment payment recognized as s. 84(3) dividend when received 316

25 September 2013 T.I. 2013-0488571E5 F - Repayment of a dividend

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Tax Topics - Income Tax Act - 81-100 - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) self-help rectification 93

10 June 2013 STEP Roundtable Q. 7, 2013-0480291C6 - 2013 STEP Roundtable Q.7 - Price adjustment clause

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5 October 2012 APFF Roundtable, 2012-0453891C6 F - Price Adjustment Clause

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24 May 2012 T.I. 2011-0429991E5

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Tax Topics - Income Tax Act - 61-80 - Section 70 - Subsection 70(5) 153

2011 APFF Roundtable Q. 4, 2011-0412071C6 F

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21 November 2011 T.I. 2011-042219 F

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Tax Topics - Income Tax Act - 81-100 - Section 84 - Subsection 84(3) price adjustment payment recognized as s. 84(3) dividend when received 52

2011 APFF Roundtable Q. 23, 2011-0412111C6 F

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28 May 2012 2010 STEP Roundtable Q. 2, 2010-0363071C6

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Tax Topics - Income Tax Act - 101-120 - Section 104 - Subsection 104(24) distribution note 149

8 October 2009 T.I. 2009-033886

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14 January 2005 T.I. 2004-010941

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18 April 2001 Memorandum 2001-006946

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10 March 1999 T.I. 5-982912

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1996 Corporate Management Tax Conference Round Table, Q.9 (CTO "Plans of Arrangement")

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1996 Calgary Round Table, Q. 17 (961680) (CTO Effective and Closing Date")

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94 CPTJ - Q.19

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92 CR - Q.30

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17 August 1992, T.I. 921353 (April 1993 Access Letter, p. 135, ¶C20-1141)

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91 CR - Q.28

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91 C.R. - Q.41

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91 CPTJ - Q.25

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16 September 1991 TI (Tax Window, No. 9, p. 9, ¶1451)

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25 February 1991 TI (Tax Window, Prelim. No. 3, p. 29, ¶1123)

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10 December 1990 TI (Tax Window, Prelim. No. 2, p. 20, ¶1065)

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90 CR - Q.58

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27 March 1990 TI (August 1990 Access Letter, ¶1364)

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Tax Topics - Income Tax Act - 1-20 - Section 15 - Subsection 15(1) 27

14 September 89 T.I. (February 1990 Access Letter, ¶1108)

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87 CR - Q.70

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85 CR - Q.52

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80 CR - Q.14

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IT-396R "Interest Income"

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IT-169 "Price Adjustment Clauses"

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IT-216 (Cancelled) "Corporation Holding Property as Agent for Shareholder" 20 May 1975

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Articles

Douglas S. Ewens, Paul Lynch, "Comments on Rectification", 2005 Conference Report, c. 23

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Darcy De Moche, Greg Johnson, "Recent Developments and Transactions Affecting Income Funds and Royalty Trusts", 2005 Conference Report, p. 17:6

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Michel Bourque, "Requirement of Notice to the Canada Customs and Revenue Agency", Tax Litigation, Vol. IX, No. 4, 2001, p. 590.

Jules Lewy, "Making Amends", CA Magazine, January/February 2002, p. 41

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Wilfred M. Estey, "Pre-Incorporation Contracts: The Fog is Finally Lifting", Canadian Business Law Journal, Vol 33, No. 1, February 2000, p. 3.

Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24, pp. 24:31-39

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Joel A. Nitikman, "When Shares are Issued", Canadian Current Tax, May 1995, Vol. 5, No. 8, p. 79.

Joel A. Nitikman, "Rescission of Contracts for Mistake", Canadian Current Tax, April 1995, Vol. 5, No. 7, p. 63.

Pound, "Remedial Tax Planning: How to Fix It When It's Broke", 1993 Conference Report, c. 9, pp. 9:19 - 21.

Kuzyk, "Selected Aspects of the Interplay Between Tax and Corporate Law", 1990 Conference Report, c. 46, 2012 DTC 1255 [at 3739]