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MNR, 93 DTC 1078, [1993] 2 CTC 2750 (TCC)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares The executors were unsuccessful in establishing that the fair market value of shares of the deceased should be discounted for the requirement under British Columbia securities law that the shares be held pursuant to an escrow agreement given that, in fact, none of the shares issued to the deceased were ever deposited in escrow. ...

MNR, 93 DTC 7, [1992] 2 CTC 2621 (TCC)-- summary under Subsection 146(6) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(6) The taxpayer's self-directed RRSP made a loan to him in the taxation year evidenced by promissory notes, and in the same year the taxpayer repaid the loan. ...

., 99 DTC 567, [1999] 2 CTC 2259 (TCC)-- summary under Subparagraph 212(1)(d)(vi) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(vi) licensing of source code used in manufacturing A lump-sum payment made for a non-exclusive licence to source code to be used by the taxpayer in manufacturing software to be sold by it was exempt under s. 212(1)(d)(vi) and under Article XII, para. 3 of the Canada-U.S. ...

., 99 DTC 567, [1999] 2 CTC 2259 (TCC)-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) lump sum payment for a non-exclusive licence was similar to royalty A lump-sum payment made in order to receive a non-exclusive licence of source code, and described as a "licence fee", was found to be "similar" to a royalty notwithstanding the absence of periodicity. ...

., 98 DTC 1377, [1998] 2 C.T.C. 2688 (TCC)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Tuition reimbursement payments received by the taxpayer from his employer (Revenue Canada) for successfully obtaining an accounting professional designation were taxable benefits to him given that the courses were taken primarily for his benefit. ...

MNR, 91 DTC 81, [1990] 2 CTC 2609 (TCC)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition The taxpayer was held to have disposed of the goodwill of his business to his sons when during the Christmas shutdown he advised his family including his two sons (who currently were involved in the business) that he was retiring, at which point he simply walked away from the business. ...

The Queen, 92 DTC 1069, [1991] 2 CTC 2645 (TCC)-- summary under Subsection 118(7) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7) Periodic amounts received by the taxpayer, who was permanently disabled, from Sun Life under the Consumers' Gas sickness, disability and rehabilitation plan were taxable under s. 6(1)(f) and did not constitute pension payments or pension benefits. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital Amounts received by the individual vendors of shares for entering into a non-compete covenant with the purchaser did not represent eligible capital amounts because the vendors were not engaged in any business. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Lump sums received by individual vendors of shares in consideration for their entering into non-competition agreements with the purchaser were characterized as being for their surrender of a potential source of profit and, therefore, represented capital receipts that were not taxable under s. 3. ...