Search - стрим ешмек шешу

The King, 2023 TCC 108-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development developing new pie recipes was SR&ED Canafric operated a food manufacturing business specializing in developing frozen pies for grocery chains and restaurants. ... Canafric averaged around six projects a year in which it would elaborate a recipe designed to meet the client’s requirements, test the recipe and send the sample product to a “taste panel” for evaluation – and evaluate the reasons for any failure. ...

Canada (Attorney General), 2025 ONCA 65-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission capital dividends were agreed to be paid in amounts that overlooked a CDA deficit: no rectification A plan was implemented for successive capital dividends to be paid up a chain of corporations so that the individual who was the ultimate shareholder could have a tax-free receipt of $1.4 million. ... …The corporate resolutions that were signed … accurately reflect the agreement. ...

PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86, aff'd [2025] HCA 30-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the “Bottler”) pursuant to which an Australian subsidiary of PepsiCo (the “Seller”) sold concentrate to the Bottler and PepsiCo granted the Bottler the right to use the Pepsi and Mountain Dew trademarks in connection with its sales of the soft drinks. Before finding that the payments made by the Bottler to the Seller were not derived by PepsiCo, so that the latter could not be subject to the Australian withholding tax on trademark royalties paid to a non-resident, Perram and Jackman JJ stated (at para. 40): It is well established that a direction by a creditor to a debtor to pay a third party constitutes a payment to the creditor. … Nevertheless, it is also recognised that there can be no payment by direction unless there is an antecedent monetary obligation owed by the Bottler to PepsiCo/SVC…. ...

.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt post-dated cheque A post-dated cheque was payable for purposes of ss. 12(1)(l) and 76(1) on its date rather than the date of delivery. ...

Canada, 99 DTC 5087, [1999] 1 CTC 132 (FCA)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer was entitled to have its expenditures treated as SR&ED notwithstanding the absence of documentary evidence relating to the repeatability of the testing data. ...

Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt indirect receipt of wages An argument was rejected to the effect that fees received by employees of a company were not wages because they were collected directly from clients of the company. ...

The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...

The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...

Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...

The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt frequent flyer points Frequent flyer points applied by the taxpayer to purchase air tickets to Chicago for medical treatment there constituted "an amount paid" for purposes of s. 118.2(2)(g). ...