in lieu of

Summary Under
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i)
amount of asset sale price allocated to actuarial surplus was includible under s. 56(1)(a)(i) as being in lieu of refund of such surplus

Before concluding that the portion of the sale price allocated on the sale of a business division to the actuarial surplus in the pension plan was...

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Words and Phrases
in lieu of
Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3)
damages received by former employees of insolvent company for cancellation of their life insurance coverage were received in lieu of remuneration for their employment services

The former employees and retirees of a bankrupt corporation (the "Employer") received a lump for the cancellation of their rights in a group...

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Words and Phrases
in lieu of arises pursuant to

Scott v. The Queen, 2017 TCC 224 -- summary under Subparagraph 56(1)(a)(iii)

Full Title
Scott v. The Queen, 2017 TCC 224
Summary Under
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(iii)
payment made as compensation for termination of monthly death benefits was paid, at the least, in lieu of a death benefit

In 1980, Nortel had established a health and welfare trust (the “HWT”) for its employees. Following its insolvency and filing under the CCAA...

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Words and Phrases
in lieu of
surrogatum principle
Summary Under
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v)
loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind

Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at...

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Words and Phrases
in lieu of on account of

Pechet v. Canada, 2009 DTC 5189, 2009 FCA 341 -- summary under Subsection 216(1)

Full Title
Pechet v. Canada, 2009 DTC 5189, 2009 FCA 341
Summary Under
Tax Topics - Income Tax Act - Section 216 - Subsection 216(1)

The non-resident taxpayer received rents from Canada in 1997 to 2001 without withholding of Part XIII tax, and in 2002 filed returns under s....

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Words and Phrases
in lieu of

Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104 -- summary under Subsection 212(1)

Full Title
Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104
Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1)
damages to lessor for advance lease repudiation were in lieu of rent

Lump-sum damages received by the non-resident taxpayer from Canadian residents for the repudiation, prior to the slated operational commencement...

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Words and Phrases
on account of
in satisfaction of
in lieu of
rent
au titre

Holzhey v. The Queen, 2008 DTC 2607, 2007 TCC 247 -- summary under Paragraph 12(1)(c)

Full Title
Holzhey v. The Queen, 2008 DTC 2607, 2007 TCC 247
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)
deemed loan proceeds reasonable substitute for accrued interest thereon

The deemed disposition by the taxpayer, as a result of his ceasing to be a resident of Canada, of a loan made by him to a non-resident corporation...

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Words and Phrases
in lieu of

Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC) -- summary under Paragraph 12(1)(c)

Full Title
Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)
sale of matured interest coupons gave rise to interest receipt or amount in lieu

An individual taxpayer, who in two successive years clipped and sold overdue coupons in the amount of $10,000 on his Canada bonds to the trustee...

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Words and Phrases
in lieu of
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