in respect of

Summary Under
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(t)
excess of relocation expenses over allowance received was deductible

A tradesperson, who satisfied the other requirements for the deduction, could deduct the difference between their accommodation expenses of $200...

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Words and Phrases
in respect of
Summary Under
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(c)
a vendor’s disclosing on its invoices the amount of meal allowances paid to its sales people transferred the 50% s. 67.1 denial onto the purchasers

The taxpayer, which sold its manufactured goods for a fixed price payable in instalments, paid reasonable meal allowances to its employees for...

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Words and Phrases
compensate specifically identified in writing in respect of

Jack Silverson, Matias Milet, Christopher Anderson, Andrew Spiro, "Canada’s Reportable Transaction Rules: A Measured Approach to Adviser Reporting", Tax Notes International, Vol. 111, No. 29, July 15, 2023 -- summary under Subparagraph 237.3(2)(c)(ii)

Jack Silverson, Matias Milet, Christopher Anderson, Andrew Spiro, "Canada’s Reportable Transaction Rules: A Measured Approach to Adviser Reporting", Tax Notes International, Vol. 111, No. 29, July 15, 2023
Summary Under
Tax Topics - Income Tax Act - Section 237.3 - Subsection 237.3(2) - Paragraph 237.2(3)(c) - Subparagraph 237.3(2)(c)(ii)
expanded reportable transaction rules should not impose reporting obligations on lawyers who negotiate contractual protection for a conventional fee

Under the revised reportable transaction rules, is a lawyer who assisted in negotiating contractual terms providing for contractual protection as...

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Words and Phrases
in respect of

Ristorante a Mano Limited v. Canada (National Revenue), 2022 FCA 151 -- summary under Paragraph 6(1)(a)

Full Title
Ristorante a Mano Limited v. Canada (National Revenue), 2022 FCA 151
Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)
"but for" test applied in determining payments were "in respect of" employment

The appellant, which operated a restaurant, paid “due-backs” to its servers representing the tips on sales processed on credit and debit cards...

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Words and Phrases
in respect of

1455257 Ontario Inc. v. Canada, 2021 FCA 142 -- summary under Paragraph 160(1)(e)

Full Title
1455257 Ontario Inc. v. Canada, 2021 FCA 142
Summary Under
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) - Paragraph 160(1)(e)
s. 160 applied to post-transfer interest

The validity of a s. 160 assessment of the taxpayer turned in part on whether the affiliate from which the taxpayer had received a transfer of...

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Words and Phrases
in respect of

Emergis Inc. v. The Queen, 2021 TCC 23, rev'd 2023 FCA 78 -- summary under Subsection 20(12)

Full Title
Emergis Inc. v. The Queen, 2021 TCC 23, rev'd 2023 FCA 78
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12)
U.S. withholding tax applicable to a tower structure did not generate a s. 20(12) deduction

The taxpayer (“Emergis”), a Canadian public company, financed its acquisition of an arm’s length U.S. operating company through a "tower...

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Words and Phrases
in respect of

Burton v Commissioner of Taxation, [2019] FCAFC 141 -- summary under Article 24

Full Title
Burton v Commissioner of Taxation, [2019] FCAFC 141
Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 24
“income” was the full U.S. gain, but FTC to be calculated based on Australian (1/2 recognition) principles

An Australian-resident individual was taxed at the 15% long-term U.S. capital gains rate on his gains on the disposal of U.S. oil and gas drilling...

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Words and Phrases
income
in respect of

Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141 -- summary under Subsection 126(1)

Full Title
Burton v Commissioner of Taxation, [2018] FCA 1857, aff'd [2019] FCAFC 141
Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1)
a foreign tax credit was reduced by ½ when only ½ of a capital gain was brought into income

The taxpayer was an Australian resident who was taxed at the 15% long-term U.S. capital gains rate on his gains on disposal of U.S. oil and gas...

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Words and Phrases
in respect of
included

Commissioner of Inland Revenue v. Lin, [2018] NZCA 38 -- summary under Article 24

Full Title
Commissioner of Inland Revenue v. Lin, [2018] NZCA 38
Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 24
Chinese tax spared on Chinese CFC income and attributed under CFC regime to New Zealand shareholder was not “in respect of” income derived by that shareholder from China

As a result of having a 30% interest between 2005 and 2009 in four companies which were resident in China, the taxpayer had the active business...

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Words and Phrases
in respect of

Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65 -- summary under Subsection 105(1)

Full Title
Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65
Summary Under
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1)
no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services

In 1998 the Canadian taxpayer paid $14.3 million to non-resident service providers in the ordinary course of its forestry business. The Minister...

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Words and Phrases
for
in respect of
retainer
fee

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