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The Queen, 96 DTC 1372, [1995] 2 CTC 2068 (TCC)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 Remuneration of $2,474 that the taxpayer (a U.S. resident) earned from employment at Simon Fraser University was exempt under paragraph 2 of Article XV of the Canada-U.S. ...

The Queen, 2010 DTC 1029 [at at 2677], 2009 TCC 624 (Informal Procedure)-- summary under Article 2 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 2 Little, J. accepted the submission of the Crown that social security charges do not qualify as taxes. ...

The Queen, 2021 TCC 49-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 2 facility for assessing injured individuals in order to report to insurers was not a health care facility, and the individuals were not “patients” The appellant (“Vocan”) provided treatment and supplied assessment reports to insurance companies or legal representatives in respect of individuals injured in motor vehicle accidents. ... II, s. 2 as a supply of an “institutional health care service” rendered to patients of the facility. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Section 42 Summary Under Tax Topics- Income Tax Act- Section 42 Lump sums received by individual vendors of shares for their execution of non-competition agreements with the share purchaser did not form part of the proceeds of disposition of their shares because their non-compete covenants did not represent "conditional obligations" i.e., obligations where there is uncertainty in respect of any of three things: "(1) whether the payment will be made; (2) the amount payable; or (3) the time at which the payment shall be made". ...

MNR, 86 DTC 1484, [1986] 2 CTC 2034 (TCC)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) purchased and leased equipment in Canada A wholly-owned U.S. subsidiary ("GLS") of another U.S. corporation ("Centra") was denied the recognition of non-capital losses on the basis that it was not carrying on business in Canada, and an indirect wholly-owned Canadian subsidiary ("McKinlay") of Centra was assessed withholding tax on rental payments made by it to GLS in respect of transportation equipment leased to it by GLS. ...

MNR, 89 DTC 451, [1989] 2 CTC 2278 (TCC)-- summary under Paragraph 2(3)(a) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(a) The taxpayer left Canada to work in Libya for an oil company, and entered into a "thrift plan" offered by the oil company under which he agreed to have 10% of his salary contributed to the plan, and the company agreed to contribute an amount equal to 15%. ...

MNR, 92 DTC 1984, [1992] 2 CTC 2367 (TCC)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) large rental complex, requiring day-to-day effort, was a business A large rental complex consisting of 158 townhouses and related facilities such as playgrounds, a large outdoor pool and a large underground parking area and that was actively managed by an independent property management company, was found to have given rise to business losses in years prior to the sale of the property by the non-resident corporate taxpayer. ...

The Queen, 2014 TCC 270, aff'd 2016 FCA 19-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part I- Section 2 marihuana is a drug but "Authorization to Possess" it is not a purchase "exemption" Hedges was assessed for his failure to charge GST on his sales of illegally produced dried marihuana to an intermediary ("BCCCS"), which in turn sold it to individual members suffering from ailments. ...

The King, 2025 TCC 70-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 2 a 20% share of a sleep clinic in the fees generated from clinic patients by physicians constituted an exempted supply to the patients by the clinic under s. ...

MNR, 91 DTC 1336, [1991] 2 CTC 2778 (TCC)-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties Assistance was derived in interpreting the Canada-U.K. ...