gift

Summary Under
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Disbursement
a directed gift is not a gift

Regarding the receipt of funds by a qualified donee that is a municipality from a registered charity where such funds would then be directed to a...

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Words and Phrases
gift
Summary Under
Tax Topics - Income Tax Act - Section 9 - Nature of Income
“gift” may be business income to the recipient

In indicating that an amount described as a “gift” could be business income to the recipient, CRA stated:

…IT-334R2[, para. 4] … states...

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Words and Phrases
gift
Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
a transfer structured as a sales agreement for nominal consideration may qualify as a gift

$1 consideration is specified in the legal documentation for a gift of property by a parent to a child solely to ensure the agreement is legally...

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Words and Phrases
gift

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36 -- summary under Paragraph 110.1(1)(a)

Full Title
Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36
Summary Under
Tax Topics - Income Tax Act - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a)
consideration for "gift" was elimination of obligation to invest the funds

The appellant was the limited partner of a partnership (“SEC”) that had become insolvent during efforts to relaunch a paper mill close to the...

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Words and Phrases
gift

Cassan v. The Queen, 2017 TCC 174 -- summary under Paragraph 69(1)(c)

Full Title
Cassan v. The Queen, 2017 TCC 174
Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
gratuitous transfer is gift irresepctive of absence of benevolent intent

In rejecting (at para. 296) a Crown submission (summarized at para. 249) that “gift” required “detached and disinterested generosity”)...

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Words and Phrases
gift

S7-F1-C1 - Split-receipting and Deemed Fair Market Value -- summary under Total Charitable Gifts

Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts

Meaning of "gift"

1.2 Under the common law, “a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no...

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Words and Phrases
gift

French v. Canada, 2016 FCA 64 -- summary under Total Charitable Gifts

Full Title
French v. Canada, 2016 FCA 64
Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts
Parliament may have intended what constitutes a gift outside Quebec to be partly informed by the Civil Code

In his 2000 to 2002 taxation years, the taxpayer made gifts to a registered charity that were funded from personal funds and from loans tied to...

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Words and Phrases
gift
Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
nature of Quebec gift

Could the acquisition of a property for consideration of one dollar qualify as an acquisition by gift for purposes of s. 69(1)(c)? The Directorate...

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Words and Phrases
gift
Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts
ability to opt out of a compulsory contribution to an employer-aligned charity would not necessarily establish a “gift”/Quebec “gift” is CCQ “donation”

A Quebec collective agreement requires each employee to annually pay a specified amount to a pre-established registered charity whose mission...

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Words and Phrases
gift don

Berry v. Warnett, [1980] T.R. 299 (C.A.), rev'd [1980] BTC 239 (HL) -- summary under Paragraph 69(1)(b)

Full Title
Berry v. Warnett, [1980] T.R. 299 (C.A.), rev'd [1980] BTC 239 (HL)
Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b)

"[T]he ordinary primary meaning of 'gift' is a voluntary transfer of property made without consideration."

Words and Phrases
gift

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