Words and Phrases - "commission"
Canada v. Rio Tinto Alcan Inc., 2018 FCA 124
The taxpayer (“Alcan”), a Canadian public company listed on the TSX and NYSE and in Europe, incurred fees (mostly of investment dealers, law...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | dealer and professional fees incurred by a public board in determining to make a bid, as contrasted to implementation, were currently deductible | 348 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) | takeover bid circular was not a financial report | 175 |
Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, aff'd 2018 FCA 124
The taxpayer, a Canadian public company listed on the TSX and NYSE and in Europe, incurred fees (mostly of investment dealers, law firms and a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 | 417 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) | legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales | 182 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) | takeover bid circular costs did not qualify | 102 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations | 365 |
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) | raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) | 246 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | failure to advance evidence showing allocation of fees to share consideration | 139 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | expenses incurred in butterfly spin-off recognized as disposition expenses | 63 |
| Tax Topics - Statutory Interpretation - French and English Version | finding common meaning of 2 versions of s. 20(1)(bb) | 108 |
Enterprise Foundry (N.B.) Ltd. v. MNR, 64 DTC 660 (TAB)
The taxpayer's business was the sale in Quebec through a Quebec sales force of stoves manufactured by an affiliated company whose manufacturing...
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|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) | employee with general authority to contract based on authorized prices and with authority over inventory in independent warehouse was PE | 289 |
Griesbach v. Canada (M.N.R.), 91 DTC 142, [1990] 2 CTC 2593 (TCC)
The taxpayer's bonuses were not "commissions" for the purposes of s. 8. Christie J. stated (at para. 5):
To my mind the result is that in order...
Consumers' Gas Co. v. MNR, 65 DTC 5138, [1965] CTC 225 (Ex Ct), briefly aff'd 67 DTC 5196 (SCC)
In connection with a rights offering the taxpayer, in addition to paying a commission to the underwriters in consideration for their services as...
MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)
In connection with the interim construction of a building, the taxpayer agreed in 1962 to pay interest on the borrowed money at a rate of 9%, plus...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 79 |