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Expense- Contract or Option Cancellation payment for surrender of key lease was capital In finding that lump sums paid by a colliery company in order to secure a reduction in the scope of (in one case) or the cancellation (in the other case) of two mining leases (and thereby release its liability to restore the surface) were on capital account, Lawrence L.J. first noted (at p. 787) that the company's trade did not consist of acquiring mining leases and selling those mining leases but, rather, of the winning and selling of coal, and then stated (at p. 788): "... it cannot, in my opinion, reasonably be said that the consideration paid for and the acceptance of the surrender was a sum wholly and exclusively expended for the purpose of winning and selling the coal in which the Company traded. ...

MacInnes & Co. and at the same time the effective elimination of that concern and its owner as a competitor. ...

. … The following provision is set out in the Taxation Regulations: 488R1… (e) an amount…that is exempt from income tax in Québec or in Canada by virtue of a provision of a tax agreement entered into with a country other than Canada; This provision is directed at avoiding double taxation and for that purpose only a tax convention concluded by Canada with another country applies to Quebec if its provisions exempt otherwise-taxable income from tax in Canada. ...

See summary under General Concepts – Rectification. ...

In rejecting the contention of Revenue that the cost of the securities to the taxpayer should be based on their fair market value at the time of acquisition rather than on the amount of the debenture and the par value at which the shares were issued, Lord Wright stated (pp. 289-290)): "... ...

In finding that foreign exchange gains or losses were realized by the taxpayer on capital account, Hill J. stated (p. 4954): "... ...

Beaubier J. stated (p. 1290): "... To be a 'specific expense incurred', it must be an explicit and identifiable expense that has been paid, or in respect to which an obligation to pay has been assumed.... ...

Revenue and Customs Commissioners, [2014] BTC 5, [2014] EWCA Civ 31-- summary under Securities Lending Arrangement Summary Under Tax Topics- Income Tax Act- Section 260- Subsection 260(1)- Securities Lending Arrangement no realistic possibility of different securities being returned/arrangement requirement broader than contractual requirement A tax avoidance scheme under which the taxpayer was targeted to receive a double deduction for accrued interest on gilts transferred to him depended on the transfer not qualifying as a "stock lending transaction," which was defined as so much of any arrangements between two persons ("the borrower" and "the lender") as are arrangements under which – (a) the lender transfers securities to the borrower otherwise than by way of a sale; and (b) a requirement is imposed on the borrower to transfer those securities back to the lender otherwise than by way of sale". ...

Warrington L.J. also stated (p. 572) that the transaction: "... is carried out in the form of a sale, but it really is the promotion of a subsidiary company to do for their own benefit and for the benefit of the parent company that which the parent company might have done if they had so pleased through agents or otherwise on their own behalf. ...

Davis stated (at p. 697): "... the section taken as a whole, which, in my opinion, is the way in which it must be interpreted, is intended to apply to persons who fall to be taxed or otherwise dealt with under the provisions of the Canadian Income Tax Act and who report to the Canadian Government the income arising from the operation of the business or businesses whose sale is the central concern of the said section 85D. ...