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During the years at issue, Reel Steel also paid the balance of its annual income to the taxpayer in the form of year-end bonuses including, in 2008, a bonus exceeding $2 million that was attributable to a large project in Vancouver. ...

The gift was intended to engage the application of s. 75(2), so that dividends on the shares would be attributed to 9134. 9134 made capital contributions of the dividends amounts received by it in 2 to 9163. 9163 then paid those funds to Satoma Trust as dividends. ...

The Queen, 2017 TCC 69, rev'd 2018 FCA 144-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) judicial nullification rather rectification of a premature capital dividend declaration gave rise to a s. 15(2) income inclusion The taxpayer was the sole shareholder and director of a Quebec corporation (``2869``) that realized an eligible capital amount on a disposition on February 2, 2008 of eligible capital property. ...

In finding that the 2009 LP was not required to accrue interest income under Reg. 7000(2)(d) respecting the linked notes in 2 above, Owen J stated (at paras. 402-3, 405): [T]he text of paragraph 7000(2)(d) requires a determination, for each taxation year to which the contingency applies, of the maximum amount of interest that could be paid in respect of that year under the terms and conditions of the debt obligation if the contingency did not exist. ...

After quoting (at para. 44) the test in Robertson (2015 TCC 246, at para. 38, aff’d 2016 FCA 303) of the conduct of a wise and prudent person: … (1) the taxpayer submits all materials to the professional advisor; (2) a discussion is had between the advisor and the taxpayer touching upon the inclusion or exclusion from income of the item; (3) that discussion gives rise to a review of the facts related to the inclusion or exclusion; and (4) a clear, factual confirmation made by the professional advisor leads to the misrepresentation. he stated: [I]t is not necessary to find that all four elements are present in order to find that a taxpayer has satisfied the “wise and prudent person” test. ...

On May 2, 2008, Mr. Colitto transferred a 50% interest in real estate (the “Properties”) to the taxpayer, Ms. ...

St-Hilaire J instead found that: The second portion of the finder’s fee did not become receivable, and was not to be recognized as income, until 2010 (in applying the test adopted “in Maple Leaf Mills to the circumstances of this case, it must be determined if and when Lockwood 1) had a right to receive compensation from LEO, and 2) had a binding agreement fixing the amount to be received from LEO” (para. 45) and “its right to receive this compensation cannot be said to have been ‘absolute and under no restriction’” in 2010 (para. 53).) ...

The King, 2023 TCC 140-- summary under Supporting Documentation Summary Under Tax Topics- Excise Tax Act- Regulations- Input Tax Credit Information (GST/HST) Regulations- Section 2- Supporting Documentation registrant not required to demonstrate that invoice received in name of supplier was in fact “issued” by it The two bakery plants of the appellant in Toronto were staffed in significant part by temporary workers (“TWs”), who were sourced from third parties (the “Agencies”), which solicited for the TWs and directed them to the appellant. ...

Given that s. 69(5) applied to this winding up, it thereby realized a capital loss on its shares of its subsidiary, which more than offset the capital gain realized by it on its transfer of Abitibi shares in 2 above, and was deemed by s. 84(2) to pay a dividend to 9101. ...

The balance of the shares of W4N now being sold directly, or through a sale of the balance of the Virtuose shares, for cash consideration of over $15 million, such that Souty Holdco and Virtuose reported capital gains of around $4.7 million each (reflecting a reduction for the ACB bump in step 1), and modest capital gains were reported by Souty and Foix on the sale of their respective shares for about $0.8 million each (having regard to their purported s. 110.6 ACB step-up in step 2 to $0.75 million). ...