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Thames Bandag & Tire Ltd. v. The Queen, 88 DTC 6417, [1988] 2 CTC 203 (FCTD)-- summary under Subsection 224(1) Summary Under Tax Topics- Income Tax Act- Section 224- Subsection 224(1) After a secured creditor ("Bandag") of a company ("Olympic") had made a demand, following the default of Olympic, on the debtors of Olympic to pay their debts to Bandag, the Crown successfully made a demand on Bandag pursuant to s. 52(10) of the Excise Tax Act. ...

Hughes & Co. Holdings Ltd., 94 DTC 6511, [1994] 2 CTC 170-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business at least six A practising lawyer who spent approximately 28 hours per year on telephone calls monitoring the business of the taxpayer in addition to making occasional visits to the taxpayer's office in consideration for annual remuneration from the taxpayer of $8,250 did not qualify as a "full-time employee". ...

Saskatoon Drug & Stationery Co. Ltd., 78 DTC 6396, [1978] CTC 578 (FCTD)-- summary under Class 13 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 13 The taxpayer acquired a leasehold interest in a drug store. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Noscitur a Sociis Summary Under Tax Topics- Statutory Interpretation- Noscitur a Sociis With respect to a submission that the more general word "management" in the phrase "management or administration fee" in s. 212(1)(a) should be coloured by the word "administration", Cullen J. stated (p. 5089): "Such an approach fails to give sufficient weight to the fact that the words 'management' and 'administration' are divided by the disjunctive 'or', which tends to suggest that the words were intended to bear separate meanings. ...

Ralston & Co., 96 DTC 6488, [1996] 3 CTC 346 (FCTD)-- summary under Paragraph 256(1)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(a) 100 voting common shares of the taxpayer were held by members of the Cohen family, and the 100 voting preferred shares of the taxpayer were held as to 50 shares by the son of the Cohen's solicitor as to the other 50 preferred shares, by the solicitor's secretary. ...

Dupont Roofing & Sheet Metal Inc. v. Canada (National Revenue), 2011 DTC 5031 [at at 5614], 2011 FC 160-- summary under Subsection 223(3) Summary Under Tax Topics- Income Tax Act- Section 223- Subsection 223(3) In finding that the taxpayer's tax debt had been properly certified, Mosley J. found that the Minister had mailed the notice of assessment but went on to note, in the alternative, that a notice of assessment was not actually required. ...

Canada(Customs & Revenue Agency), 2004 DTC 6057, 2004 FC 46-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) The Minister's decision not to waive penalties for the late filing of a return was remitted for redetermination given that such decision did not appear to take into account various relevant factors including the assertion of the taxpayer (corroborated by her accountant) that the return had been prepared and mailed on time, the indication on the return that it was prepared before the filing date, and her good compliance history up until the time in question when she was under serious emotional and mental distress. ...

Damka Lumber & Development Ltd. v. The Queen, 90 DTC 6101, [1990] 1 CTC 127 (FCTD)-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (d) Although the taxpayer sold its property to an agent acting for an undisclosed principal (which was the Urban Transit Authority of British Columbia) in the belief that if it did not sell the property would be expropriated, it was not told that the British Columbia government or any government body which was behind the attempted acquisition would so expropriate and, in fact, the Urban Transit Authority did not at that time have statutory authority to expropriate. ...

Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) For financial statement purposes, the taxpayer, whose business was the processing of silver, used a perpetual inventory costing system under which inventory was carried at the same cost as at the previous year-end or, in the case of net additions to inventory, at the lowest cost at which purchases were made in the year. ...

Stevenson & Hunt Insurance Brokers Ltd. v. The Queen, 93 DTC 5125, [1993] 1 CTC 383 (FCTD), briefly aff'd 98 DTC 6383 (FCA)-- summary under Paragraph 12(1)(b) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) Contingent profit commissions, which an insurance broker was entitled to receive from insurance companies in respect of its 1983 fiscal year and that were contingent on the insurance companies' profitability on policies sold by the broker, did not constitute amounts receivable by the broker at the end of that fiscal year given the impossibility of coming to a reasonable estimate of the amount of those commissions at the end of the fiscal year. ...