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The Queen, 89 DTC 5333, [1989] 2 CTC 75 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by unauthorized agent not payment On November 24, 1980 the Department of Supply and Services issued a refund cheque to "Cumberland Properties Ltd. c/o John Church", which was the manner in which Cumberland's 1978 return had been completed. ...

Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as payment The wholly-owned Canadian subsidiary of the taxpayer declared a dividend, with the resolution stipulating that the dividend was "to be payable by the Corporation by the issuance of a demand promissory note". ...

Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, a producer of plastic containers, undertook a project to "improve the existing product to make it a smaller and significantly lighter storage system" (para. 9 of Statement of Appeal, quoted at para. 5). ...

., 97 DTC 5252, [1997] 2 CTC 286 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission retroactive effect of nunc pro tunc rectification order The taxpayers neglected to have shares that purportedly were issued to them in 1985 added to the authorized capital of the issuing corporation. ...

Canada, 2022 FCA 72-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development need for use of the scientific method in SR&ED In response to the taxpayer’s submission that the Tax Court judge erred in relying on the test from Northwest Hydraulic in that it was not a requirement for SR&ED eligibility that the scientific method be followed, and that the scientific method contemplated by Northwest Hydraulic and applied by the judge differed from the engineering method, Rennie JA indicated: Kam-Press “affirmed that the Northwest Hydraulic criteria are the appropriate interpretation of the definition of scientific research and experimental development in subsection 248(1)” (para. 9). ...

John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) In obiter dicta it was suggested that lump-sum payments for a non-exclusive licence to use computer programs in the design of ships were covered by s. 106(1)(d)(i) of the pre-1972 Act. ...

Johnson & Johnson Inc. v. D.MNR, 88 DTC 6235, [1988] 2CTC 1 (FCTD)-- summary under Interpretation Bulletins, etc. ...

Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)-- summary under Subsection 45(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 45(2) A comparison of s. 256(1)(e) with s. 39(4) of the pre-1972 Act helped establish that in s. 256(1)(e) Parliament intended that the shareholding of one member of a group was insufficient to fulfill the cross-shareholding requirement in s. 256(1)(e). ...

Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) Before finding against the taxpayer on other grounds, the Court accepted that the reference to "contingent account" refers to accounting practice. ...

Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA)-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property Notwithstanding the terms of a contract between the taxpayer and an insurance company, funds received by the taxpayer from clients were treated by it and the insurance company as being its property, and that therefore was the characterization to be given to those funds for purposes of the Act. ...