Cases
Industries Perron Inc. v. Canada, 2013 FCA 176
The taxpayer ("Perron") made cash term deposits in connection with its potential liability for countervailing and anti-dumping duties imposed by...
De Graaf v. The Queen, 85 DTC 5280, [1985] 1 CTC 374 (FCTD)
The taxpayer disposed of a property and reported a business loss in his 1975 tax return. In computing the loss, the taxpayer deducted from the...
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 71 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 36 |
Canada v. General Motors of Canada Ltd., 2008 DTC 6381, 2008 FCA 142
A collective agreement between the taxpayer and the CAW, as amended by them following the decision of the Federal Court of Appeal for the earlier...
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| Tax Topics - General Concepts - Evidence | parol evidence excluded | 261 |
Canada v. McLarty, 2008 DTC 6354, 2008 SCC 26, [2008] 2 S.C.R. 79
The full purchase price of $100,000 for the acquisition by the taxpayer of seismic data represented Canadian exploration expense to him...
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| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | decision making not subordinated to the other/ structured arrangement | 138 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (a) | limited recourse promissory note | 187 |
General Motors of Canada Ltd. v. Canada, 2004 DTC 6716, 2004 FCA 370
Under a collective agreement with its union, the taxpayer agreed to accrue $2 per every overtime hour worked by covered employees in excess of 5%...
Wawang Forest Products Ltd. v. The Queen, 2001 DTC 5212, 2001 FCA 80
If the taxpayer paid a logging contractor in full upon delivery to it of cut wood, it would be subject to liability to the workers' compensation...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 362 |
Ticketnet Corp. v. R, 99 DTC 5409, [1999] 3 CTC 564 (FCTD)
The taxpayer agreed with Air Canada that: Air Canada would develop a software program for a price of $2 million; for the first five years...
Canadian Pacific Ltd. v. Minister of Revenue (Ontario), 99 DTC 5286, 41 OR (3d) 606 (Ont CA)
Upon receipt of notice of an award by the Workman's Compensation Board, the taxpayer would calculate the amount of the award on the basis of the...
B. Jolly Enterprises Ltd. v. The Queen, 94 DTC 6636, [1994] 2 CTC 379 (FCA)
In finding that a corporate taxpayer was not entitled to deduct expenses incurred prior to its formation and pursuant to an alleged contract...
The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607, [1990] 2 CTC 448 (FCA)
The taxpayer, which had incurred various expenses in respect of the second phase of a pipeline project which had not yet been constructed, was...
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 95 | |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 181 |
Wil Mechanical Ltd. v. The Queen, 90 DTC 6475, [1990] 2 CTC 224 (FCTD)
Although the taxpayer, as the subcontractor on various jobs, withheld 15% from the amounts it paid to the sub-subcontractors until, generally, the...
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| Tax Topics - General Concepts - Evidence | 92 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | subcontractors entitled to holdback amounts | 83 |
Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)
Before finding against the taxpayer on other grounds, the Court accepted that the reference to "contingent account" refers to accounting practice.
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 111 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | liability re holdback amounts not yet ascertained | 79 |
Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153, [1989] 1 CTC 363 (FCTD)
Northern Central Gas was followed. Teitelbaum J. noted (p. 5167) that although "where amounts are put into reserve accounts to cover liabilities...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve for revenues collected at excess rate | 98 |
| Tax Topics - Income Tax Act - Section 9 - Timing | future obligation for offsetting tariff reduction | 108 |
TNT Canada Inc. v. The Queen, 88 DTC 6334, [1988] 2 CTC 91 (FCTD)
At the end of its 1980 taxation year, the taxpayer (a common carrier) deducted $125,385 for the total of cargo claims which had been filed against...
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| Tax Topics - General Concepts - Accounting Principles | 50 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 113 |
Sears Canada Inc. v. The Queen, 86 DTC 6304, [1986] 2 CTC 80 (FCTD), aff'd 89 DTC 5039 (FCA)
Sears included in income amounts which it received from customers for its agreement to maintain and repair the sold products for a further year...
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| Tax Topics - General Concepts - Accounting Principles | 28 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | reserve can be for contingent amounts | 46 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(7) - Paragraph 20(7)(a) | 68 |
Northern and Central Gas Corp. Ltd. v. The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA)
It was anticipated by the taxpayer that in its 1978 taxation year it would be required by the Ontario Energy Board to pass along to its customers...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 2 | 65 | |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 | 65 |
Consolidated-Bathurst Ltd. v. The Queen, 85 DTC 5120, [1985] 1 CTC 142 (FCTD), aff'd on different grounds, 87 DTC 5001, [1987] 1 CTC 55 (FCA)
Semble, that "insurance" premiums paid by the plaintiff to an arm's-length Canadian insurance company, which in turn re-insured various risks with...
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| Tax Topics - General Concepts - Tax Avoidance | 42 | |
| Tax Topics - Income Tax Act - Section 138 - Subsection 138(1) - Paragraph 138(1)(a) | 38 |
Amesbury Distributors Ltd. v. The Queen, 85 DTC 5076, [1984] CTC 667 (FCTD)
A distributor of television sets charged dealers a flat fee of $30 per set in return for providing after-sales servicing of the sets under a...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(7) - Paragraph 20(7)(a) | 44 |
Cummings v. The Queen, 81 DTC 5207, [1981] CTC 285 (FCA)
Since the liability of the taxpayer at the end of its 1968 taxation year to pay $500,000 to a prospective tenant was contingent inter alia upon...
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| Tax Topics - General Concepts - Accounting Principles | 94 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | landlord assumption of old leases | 82 |
McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)
As at the end of each fiscal year a company accrued the amount of a management bonus, and during the following year the company's...
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 42 |
Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA)
Sales of books were made each year by the taxpayer to a distributor. The taxpayer was obligated to repurchase any books which the distributor...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) | 92 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | no bad debt history | 44 |
Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)
Insurance premiums were payable each year by the taxpayer pursuant to a Lloyds policy which established the premiums payable for each year in...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 53 |
The Queen v. Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)
Kerr, J. indicated, obiter, that s. 18(1)(e) would have applied to unpaid bonuses which the taxpayer sought to deduct: "When the decision to pay...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | gratuitous bonus | 84 |
Mister Muffler Ltd. v. The Queen, 74 DTC 6615, [1974] CTC 813 (FCTD)
Reserves set up for a "guarantee" to replace mufflers installed by the taxpayer were implicitly treated as a contingent account.
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(7) - Paragraph 20(7)(a) | agreement to replace any defective installed muffler was warranty etc. | 122 |
The Queen v. Jawl Industries Ltd., 74 DTC 6133, [1974] CTC 147 (FCTD)
The price of lumber declined after the taxpayer contracted to purchase lumber at a stipulated price for delivery in a subsequent taxation year....
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 35 |
J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC)
A general building contractor in accordance with the terms of its contracts with its subcontractors withheld 10% of the amounts invoiced on a...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 91 | |
| Tax Topics - Statutory Interpretation - Certainty | 62 |
Lawson v. Minister of National Revenue, 69 DTC 5155, [1969] CTC 201, [1969] S.C.R. 587
It was submitted on behalf of a mining stock promoter that he should be permitted to follow the "project" method of accounting in determining the...
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| Tax Topics - General Concepts - Fair Market Value - Shares | 106 | |
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | 200 |
Time Motors Limited v. Minister of National Revenue, 69 DTC 5149, [1969] CTC 190, [1969] S.C.R. 501
The taxpayer, which was a used car dealer, issued credit notes in partial payments of used cars acquired for resale. The notes were not...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 112 |
Meteor Homes Ltd. v. MNR, 61 DTC 1001, [1960] CTC 419 (Ex. Ct.)
Kearney J. rejected a submission that a retail sales tax liability of the taxpayer (whose payment had not yet been demanded by the Québec...
Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)
Thorson J., before finding that the taxpayer could exclude unearned insurance premiums from its income on other grounds, stated, with respect to...
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| Tax Topics - Income Tax Act - Section 9 - Timing | 304 |
See Also
Industries Perron Inc. (anciennement 3654419 Canada Inc.) v. The Queen, 2012 DTC 1072 [at 2836], 2011 TCC 433, aff'd 2013 FCA 176
Angers J. denied the taxpayer's deduction of a reserve it made in respect of preliminary anti-dumping rulings against it from the International...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(vv) | 239 |
Fèdèration des Caisses Populaires Desjardins, 2000 DTC 1585 (TCC), rev'd on second (statutory contribution) issue 2002 DTC 7413 (FCA)
The employees of the taxpayer earned vacation leave during a reference period running from May 1 to April 30 each year. When they took their...
Dibro Investments Ltd. v. MNR, 87 DTC 210, [1987] 1 CTC 2281 (TCC)
Although the taxpayer was obligated to pay 10% of its revenues to its franchisor, it was held these payments in the taxation years in question in...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | liability incurred notwithstanding subsequently negotiated reduction | 104 |
Barbican Properties Inc. v. The Queen, 97 DTC 122, [1996] 2 CTC 2615 (TCC), briefly aff'd 97 DTC 5008 (FCA)
The taxpayer financed the purchase of "distressed" properties from the Royal Bank through non-recourse loans received from the Royal Bank which...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 138 |
Alfred Dallaire Inc. v. MNR, 96 DTC 1094, [1996] 1 CTC 2218 (TCC)
The taxpayer, which ran a funeral home business and agreed with many of its customers to provide the required funeral services on each customer's...
Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)
Before going on to affirm a finding of the special commissioners that the taxpayer was entitled to accrue in advance the cost of periodic major...
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| Tax Topics - Income Tax Act - Section 9 - Timing | 203 |
I.B. Pedersen Ltd. v. The Queen, 94 DTC 1085, [1994] 1 CTC 2355 (TCC)
The taxpayer, which operated a waste landfilled site, was required to include in income the full amount of fees received from a municipality for...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no deduction for future remediation work | 55 |
Co-operator's General Insurance Co. v. MNR, 92 DTC 303 (TCC)
Brulé J. found that the amounts deducted by the taxpayer in excess of the amounts actually payable in the year pursuant to the formula in the...
Pioneer Designs Corp. v. MNR, 91 DTC 293, [1990] 2 CTC 2446 (TCC)
Before finding accrued bonuses to be deductible, Garon TCJ. stated (p. 300): "No authority has been cited to me that would require ... the...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) | 67 |
Dunblane Estates Ltd. v. MNR, 89 DTC 137, [1989] 1 CTC 2248 (TCC)
The taxpayer was obligated under its collective agreement to let employees claim against their accrued and unused sick leave credits when they or...
Southern Pacific Insurance Co. Ltd. v. C.I.R., [1986] BTC 181 (PC)
It was held in relation to an insurance company that "the amount of the liability of the company for accidents which occurred but were not...
Fred Nesbit Distributing Co. v. U.S., 85-2 USTC 89580 (D.C. Iowa)
The taxpayer, which was a wholesale beer distributor, collected a deposit when it sold beer to dealers, and the dealers were required by law to...
Canada Packers Ltd. v. MNR, 68 DTC 682 (TAB)
Because the taxpayer's fiscal year ended in the last Saturday in March of each year, it was possible for it to pay holiday pay for two Good...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | 128 |
Quebec Photo Service Inc. v. MNR, 67 DTC 315 (TAB)
The taxpayer credited to a special account for each employee an amount equal to a half-day's salary for every month of employment, which the...
Acadia Overseas Freighters Halifax Ltd. v. MNR, 62 DTC 84 (TAB)
Under the terms of its contracts of employment with Lascar seamen, the taxpayer undertook to pay the cost of transporting them to their native...
Capital Transit Ltd. v. MNR, 52 DTC 287 (ITAB)
The taxpayer, the operator of a bus service, credited all sales of tickets to a liability account, and took such amounts into income only when the...
J.J. Joubert Limité v. MNR, 52 DTC 317 (ITAB)
In finding that the taxpayer, a milk distributor, was not entitled to deduct amounts previously received by it represented by unredeemed prepaid...
Administrative Policy
28 January 2021 Internal T.I. 2019-0817641I7 - Acquisition of rights to pension surplus
A portion of the purchase price paid for the acquisition of a business of the Seller by the Purchaser was allocated to the actuarial surplus in a...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Actuarial Surplus | CRA finds that the purchase price of a business allocated to the actuarial surplus for a defined benefit plan was a non-deductible capital expenditure | 517 |
| Tax Topics - Income Tax Act - Section 78 - Subsection 78(4) | s. 78(4) exclusion would apply to the purchase of actuarial surplus | 191 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(35) | purchased actuarial surplus was not deemed goodwill under s. 13(35) | 222 |
S2-F1-C1 - Health and Welfare Trusts
1.50 Although actuarial studies of the trust may recommend the establishment of contingency reserves to meet its future obligations, transfers to...
22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities
the correspondent noted that under the GAAP that prevailed in 2008 (contained in Section 3855 of the CICA Handbook) taxpayers whose financial...
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | financial liabilities not to be marked to market | 138 |
| Tax Topics - Income Tax Act - Section 9 - Timing | liabilities not to be marked to market | 138 |
4 May 2010 External T.I. 2009-0329391E5 F - Provision pour retour de marchandises
The contracts for sales by a book publisher to its customers provide that books which have not been sold within 12 months may be returned. Would a...
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| Tax Topics - Income Tax Act - Section 9 - Timing | no profit required to be recognized on delivery of goods where a "true" return of unsold goods clause | 76 |
26 August 2005 Internal T.I. 2005-0131171I7 F - Alinéa 18(1) e) de la LIR
A maintenance obligation to landlords did not give rise to a current deduction since no contractual obligation with specific counterparties had...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | no expense incurred for maintenance obligation until contractual obligation to someone | 80 |
20 October 2004 Internal T.I. 2004-0086501I7 F - Droits compensateurs
In 2001, the U.S. government began imposed countervailing and anti-dumping duties ("CADD") on the export of softwood lumber products from Canada,...
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(vv) | posting of bonds for US countervailing duties did not constitute their being “paid” for s. 20(1)(vv) purposes | 264 |
28 January 2004 External T.I. 2003-0028891E5 F - Perte sur change relative à des contrats de change
A corporation had an accrued foreign exchange loss on foreign exchange contracts that it had entered into to hedge its food-sale operations in the...
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | CGE established that accrued loss on FX forward contract is not a contingent liability | 191 |
16 July 2003 Internal T.I. 2003-0024617 F - DEDUCTIBILITE DES COTISATIONS CSST
The taxpayer recorded an estimate of the workers’ compensation (“CSST”) premium liabilities it had incurred in the year, which was prior to...
11 June 2002 External T.I. 2001-0104075 F - DEDOMMAGEMENT
Regarding whether an award of damages against the taxpayer in connection with its construction of a manufacturing plans was contingent and, thus,...
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| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | damages award not part of cost if subject to an appeal | 138 |
11 April 2000 Internal T.I. 2000-0001327 - INDEX LINKED GIC CONTINGENT LIABILITY
s. 18(1)(e) would prohibit the deduction by the issuer of the premium on a TSE-certified-linked GIC until the time of payment on maturity...
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 38 |
16 February 1999 External T.I. 9900535 - RESERVES
A reserve fund for future utility costs that a water utility is required to set up pursuant to s. 57 of the Utilities Commissions Act (B.C.) does...
5 February 1996 External T.I. 9528445 - DEDUCTIBILITY OF REPAYABLE INCOME AMOUNTS
Discussion as to whether an amount that a physician billed over the statutory cap on his billings would be deductible prior to the year of repayment.
25 July 1994 External T.I. 9405605 - U.S. COUNTERVAILING DUTY ON CANADIAN SOFTWOOD LUMBER
U.S. countervailing duty cash deposits paid by Canadian lumber companies would be refundable deposits and, therefore, would represent...
18 November 1992 Memorandum 921979 (September 1993 Access Letter, p. 407, ¶C9-286)
A reserve for vacation pay benefits earned by employees in the year and that are reasonably expected to be taken in the following year does not...
30 November 1991 Round Table (4M0462), Q. 5.1 - Acquisition of a Business (C.T.O. September 1994)
Discussion of the treatment of a purchaser that on the acquisition of a business assumes responsibility for liabilities that have not been...
91 CPTJ - Q.16
Although there is no provision of Part I permitting the deduction of accruals for site restoration costs, a payment to a government-mandated site...
90 C.R. - Q14
S.18(1)(e) prohibits the deduction by a mining company on an accrual basis of future removal and site restoration costs.
19 October 89 T.I. (March 1990 Access Letter, ¶1140)
The accrual by a corporation in respect of its obligation to provide pension benefits to an employee who would retire in five years would not be a...
IT-215R "Reserves, Contingent Accounts and Sinking Funds"
IT-467R "Damages, Settlements and Similar Payments"
A reserve or contingent liability for anticipated damages is not deductible.
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
CCAA Stay does not generate a s. 18(1)(e) contingency (p. 13:32)
[W]hile a stay under the CCAA stays proceedings with respect to damage claims,...
Hirsch, "Real Estate Issues: Traps and Opportunities", 1995 Corporate Management Tax Conference Report, c. 9
Discussion of issues respecting the allocation of common costs for which no legal liability has yet been incurred.
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | 30 |
Holmes, "Supplemental Retirement Arrangements May Provide Deferral for Employee and Deduction for Employer", Taxation of Executive Compensation and Retirement, March 1990, p. 243
Where the amount of pension under a supplemental plan that is payable to an executive may not be ascertainable until the executive retires, it...
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| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(a) | 57 |