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., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement 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. ...

The Queen, 97 DTC 449, [1996] 2 CTC 2269 (TCC)-- summary under Section 32 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 32 s. 32 deals with departures from form rather than content S.32 was of no assistance to cure a purported election under s. 39(4) because "section 32 is concerned with variations in the form itself and not with its content" (p. 452) whereas the taxpayer had used the prescribed form but without the required content. ...

The Queen, 95 DTC 634, [1995] 2 CTC 2543 (TCC)-- summary under Subsection 212.1(1) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(1) Bell TCJ. found on the basis of the testimony of various executives that shares of a Canadian corporation ("OJC") were acquired by the taxpayer's U.S. payment as agent for the taxpayer. ...

., 97 DTC 1097, [1997] 2 CTC 2748 (TCC)-- summary under Subsection 84(1) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(1) shares satisfied liability for services The issuance to the taxpayer of shares having a paid-up capital of $350,000 did not give rise to a deemed dividend because they were in respect of past services he had provided to the corporation having an agreed value of the same amount. ...

MNR, 91 DTC 1113, [1991] 2 CTC 2352 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Lease inducement payments received by a holding company in connection with obtaining leases of office space which it, in turn, would provide to its operating subsidiaries, were found to have been received by it on income account based on a finding that it entered into the leases as part of its day-to-day business operations. ...

MNR, 92 DTC 1743, [1992] 2 CTC 2146 (TCC)-- summary under Qualified Expenditure Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Qualified Expenditure After finding that the Act made reference to expenditures (or expenses) made in contradistinction to expenditures (or expenses) incurred, Garon J. found that salaries which were accrued in one year but were not paid until the subsequent taxation year did not constitute "qualified expenditures" in the year of accrual. ...

MNR, 90 DTC 1834, [1990] 2 CTC 2351 (TCC)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 vending stand used 3 weeks per year was PE A U.S. resident, who every year sold knives and kitchen devices at a stand at the Vancouver Pacific National Exhibition for several weeks, was found to be carrying on business in Canada through a permanent establishment for purposes of the Canada-U.S. ...

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) Beaubier, J. followed the decision in Apfelbaum v. ...

The Queen, 93 DTC 953, [1993] 2 CTC 2409 (TCC)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency A wife was found not to have engaged in transactions (which were part of an arrangement for income splitting with her husband) as agent for her husband given that she was motivated by a desire for more income for herself and was a more enthusiastic participant in the transactions than her husband. ...

MNR, 92 DTC 1769, [1992] 2 CTC 2119 (TCC)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits Microwave ovens and coffee brewers used by customers of the taxpayer's coin-operated vending machines in order to heat such products as hotdogs, hamburgers and pizzas, or to brew coffee, were not used for the "processing" of goods. ...