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Hewitt & Sons Ltd. v. The Queen, 2000 DTC 2441 (TCC)-- summary under Subsidiary Controlled Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Subsidiary Controlled Corporation 40%f the shares of a Bahamian affiliate ("Bahamas") of the taxpayer were owned by the taxpayer and 60% of the shares of Bahamas were owned by another Bahamian corporation ("Abaco"). ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)-- summary under Subsection 5903(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903- Subsection 5903(3) A U.S. resident corporation ("Trans World U.S. ...

Roman Miniotas (Romeo’s Plumbing & Heating) v. The Queen, 2011 DTC 1078 [at at 420], 2011 TCC 43-- summary under Subsection 167(5) Summary Under Tax Topics- Income Tax Act- Section 167- Subsection 167(5) The taxpayer's accountant sent letters on 3 and 24 October 2007, appealing an assessment. ...

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 152(1.12) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.12) The Minister made an assessment under s. 152(1.11) on the basis that the GAAR applied to reduce the paid-up capital of shares of a Canadian holding company ("Holdings") from $167 million to $475,000, and about ten days later assessed on the basis that previous purported distributions of about $104 million of paid-up capital ("PUC") by Holdings were subject to Part XIII tax. ...

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 A review of a law firm's accounts in 2005 revealed that accounts had been rendered in 2002, 2003 and 2004 which were uncollectible and which had not been written off. ...

The Humber College Institute of Technology & Advanced Learning v. ...

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) limited scope of PUC provisions reflected a policy choice The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...

D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) stock dividend by dividend payer did not reduce the safe income attributable to its subsidiary After a preliminary reorganization, all of the shares of the taxpayer (consisting of Class A common shares and Class D preference shares) were owned by another Canadian corporation ("HLL"), whose safe income on hand ("SIOH") respecting the taxpayer was $1.493M, comprised of safe income earned by the taxpayer of $0.976M and safe income of $0.517M in respect of the taxpayer's 50% shareholding of another Canadian corporation ("RTI"). ...

., the identity of the debtor, the principal amount, the amount of interest and the maturity date” identified in General Electric Capital, “ the only term that was significantly different in respect of the Post-Auction Debt … was the amount of interest.” However, although thus “there was not a disposition in 2011 of the Pre-Auction Debt” (para. 105), he had previously stated (at para. 86): [S]ubparagraph (b)(i) of the definition of “disposition” … states that “‘disposition’ of any property … includes … any transaction or event by which, … where the property is a … mortgage, … the property is in whole or in part redeemed, acquired or cancelled….” … Thus, by reason of the foreclosure and the judicial sale, the Mortgage was cancelled. ...