The Queen v. TCG International Inc., 96 DTC 6547 (FCTD)

In finding that the decision of the Court of Appeal in the Ikea case established that a tenant inducement payment received by the taxpayer was fully taxable, Gibson J. stated (at p. 6549):

"No distinction can be drawn from the fact that the premises here in question were head office premises, as opposed to wholesale and retail sales outlet premises. I am satisfied that head office activities and the premises at which those activities are carried on are equally as integral to the business operations of a limited company such as the Defendant as are wholesale and retail premises."

In finding that the decision of the Court of Appeal in the Ikea case established that a tenant inducement payment received by the taxpayer was fully taxable, Gibson J. stated (at p. 6549):

"No distinction can be drawn from the fact that the premises here in question were head office premises, as opposed to wholesale and retail sales outlet premises. I am satisfied that head office activities and the premises at which those activities are carried on are equally as integral to the business operations of a limited company such as the Defendant as are wholesale and retail premises."