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T Rev B decision
Gaston C Payette, Appellant, >>and And. >>minister of National Revenue, Respondent., [1978] CTC 2223, 78 DTC 1181
The financial results of 1966 to 1973, as submitted by the respondent, and not contradicted by counsel for the appellant, were as follows: Sa/es Sales Expenditures Losses in book business 1966 $4,872.24 $17,417.77 $12,545.53 1967 $2,308.92 $ 7,402.34 $ 5,093.42 1968 $4,150.10 $12,392.26 $ 8,242.16 1969 $8,428.46 $17,813.55 $ 9,385.09 1970 $3,427.24 $12,871.40 $ 9,444.16 1971 $6,723.02 $17,417.14 $10.694.12 1972 $2,822.90 $12,740.21 $ 9,918.31 1973 $ 734.16 $ 9,653.13 $ 8,918.97 3.8. ... The following is the appellant’s statement of income and expenditure for 1971, given as a typical example of the various expenditures which explained the appellant’s losses with regard to the publication and sale of his books: Net sale of books $ 6,723.82 Harpell Press: purchase of books $ 3,475.00 New York Times: advertising $ 6,260.50 Book World: advertising $ 1,415.63 Consumption [sic] of books $ 78.65 Printing of circulars $ 289.18 Clerical costs $ 3,000.00 A&C annuities and pensions, illness $ 99.72 Travel: book business $ 3,059.68 Bank charters $ 21.96 Nat photoengraving, text illustration S 419.71 C Podlone: text revision $ 360.00 Stationery $ 348.60 Bell Tel $ 31.38 Burnett, Appleby: purchase of names $ 225.40 Postage $ 943.53 $20,028.94 Increase in inventory $ 2,611.00 $17,417.94 Losses of book business $10,694.12 This statement of income for 1971 was admitted by the respondent as being representative of the other years concerned. 3.14. ...
Decision summary
Formula One World Championship Ltd v. Commissioner of Income Tax, International Taxation – 3, Delhi & Anr. (2017), Civil Appeal No. 3849 of 2017, 15 SCC 602 -- summary under Article 5
The place would be treated as ‘at the disposal’ of the enterprise when the enterprise has right to use the said place and has control thereupon. … [The] Buddh International Circuit is a fixed place. From this circuit different races, including the Grand Prix is [sic] conducted, which is undoubtedly an economic/business activity. … Respecting whether the circuit was a fixed place of business of FOWC, he referenced the control rights accorded to FOWC under the Service Agreement, and stated (also at para. 67): … The … arrangement clearly demonstrates that the entire event is taken over and controlled by FOWC and its affiliates. ... All these are controlled by FOWC and its affiliates. … Omnipresence of FOWC and its stamp over the event is loud, clear and firm. … [A] commonsense and plain thinking of the entire situation would lead to the conclusion that FOWC had made their earning in India through the said track over which they had complete control during the period of [the] race. ...
Technical Interpretation - Internal summary
21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback Surplus & PAS election -- summary under Subsection 220(3.2)
21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback Surplus & PAS election-- summary under Subsection 220(3.2) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.2) no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...
Technical Interpretation - Internal summary
21 April 2015 Internal T.I. 2014-0560811I7 - FACL carryback Surplus & PAS election -- summary under Regulation 600
21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback Surplus & PAS election-- summary under Regulation 600 Summary Under Tax Topics- Income Tax Regulations- Regulation 600 no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...
Technical Interpretation - External summary
7 February 1994 External T.I. 9309865 F - 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus -- summary under Subsection 5902(2)
7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus-- summary under Subsection 5902(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5902- Subsection 5902(2) Where a corporation resident in Canada owns 95% of the common shares of FA1 which, in turn, owns 100% of the common shares of FA2 which, in turn, owns 5% of the commons shares of FA1, and the Canadian corporation disposes of its shares of FA1 to a third party and elects under s. 93(1), FA2 will be the particular foreign affiliate for the purposes of Regulation 5902(2)(a). ...
Technical Interpretation - External summary
23 June 2014 External T.I. 2014-0528271E5 F - Terrain « adjacent » à la résidence principale -- summary under Principal Residence
23 June 2014 External T.I. 2014-0528271E5 F- Terrain « adjacent » à la résidence principale-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence meaning of immediately contiguous lands The taxpayers, whose "Lot 1" included a floodplain, were legally precluded from expanding their residence until they purchased the nearby "Lot 2. ...
Conference summary
15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F - IFA 2020 Roundtable – T2057 & Functional Currency -- summary under Paragraph 261(5)(a)
15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency-- summary under Paragraph 261(5)(a) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(5)- Paragraph 261(5)(a) different currency reporting of s. 85(1) rollover where one party has elected a functional currency CRA indicated that where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), it would require that two separate forms T2057 be filed. ...
Decision summary
Kucor Construction & Developments & Associates v. Canada Life Assurance Co. (1998), 41 OR (3d) 577 (Ont. C.A.) -- summary under Ownership
Kucor Construction & Developments & Associates v. Canada Life Assurance Co. (1998), 41 OR (3d) 577 (Ont. ...
Decision summary
Lanman & Kemp-Barclay & Co. of Colombia v. Commissioner of Internal Revenue, 26 TC 582 (1956) -- summary under Non-Business-Income Tax
Lanman & Kemp-Barclay & Co. of Colombia v. Commissioner of Internal Revenue, 26 TC 582 (1956)-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The Republic of Colombia levied, pursuant to the same tax statute under which an income tax and an excess profits tax was levied, a capital tax (referred to as a "patrimony tax") which was "based on the theory that the income tax, in order to be an equitable revenue system, requires a tax on capital to more fairly distribute the burdens amongst the nation's taxpayers and to prevent the state from being penalied if a property owner, through negligence or for some other reason, fails to realize the inherent productive potential of his property" (p. 587). ...
Conference summary
3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6 - 2022 CALU – Q10 – Private Health Services Plan -- summary under Subparagraph 6(1)(a)(i)
3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) single shareholder/employee HSA does not qualify S. 6(1)(a)(i) excludes a taxable benefit from the employer’s funding of a private health services plan (PHSP) for its employees, including in the case of a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit). ... This is based on its view that “for a plan to be a PHSP … the plan must be a plan of insurance” and, here, “[e]ffectively, the sole employee-shareholder is paying for the personal hospital and medical expenses for themselves and their family members through their solely owned corporation without any risks being assumed by the corporation.” ...