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TCC (summary)

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) -- summary under Paragraph 20(1)(e)

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...
TCC (summary)

R.A. Hewitt & Sons Ltd. v. The Queen, 2000 DTC 2441 (TCC) -- summary under Subsidiary Controlled Corporation

Hewitt & Sons Ltd. v. The Queen, 2000 DTC 2441 (TCC)-- summary under Subsidiary Controlled Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Subsidiary Controlled Corporation 40%f the shares of a Bahamian affiliate ("Bahamas") of the taxpayer were owned by the taxpayer and 60% of the shares of Bahamas were owned by another Bahamian corporation ("Abaco"). ...
TCC (summary)

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1 -- summary under Shares

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...
TCC (summary)

Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA) -- summary under Subsection 5903(3)

Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)-- summary under Subsection 5903(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903- Subsection 5903(3) A U.S. resident corporation ("Trans World U.S. ...
TCC (summary)

Roman Miniotas (Romeo’s Plumbing & Heating) v. The Queen, 2011 DTC 1078 [at at 420], 2011 TCC 43 -- summary under Subsection 167(5)

Roman Miniotas (Romeo’s Plumbing & Heating) v. The Queen, 2011 DTC 1078 [at at 420], 2011 TCC 43-- summary under Subsection 167(5) Summary Under Tax Topics- Income Tax Act- Section 167- Subsection 167(5) The taxpayer's accountant sent letters on 3 and 24 October 2007, appealing an assessment. ...
TCC (summary)

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251 -- summary under Subsection 152(1.12)

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 152(1.12) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.12) The Minister made an assessment under s. 152(1.11) on the basis that the GAAR applied to reduce the paid-up capital of shares of a Canadian holding company ("Holdings") from $167 million to $475,000, and about ten days later assessed on the basis that previous purported distributions of about $104 million of paid-up capital ("PUC") by Holdings were subject to Part XIII tax. ...
TCC (summary)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure) -- summary under Subparagraph 20(1)(p)(i)

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) subsequently discovered bad debts not claimable; unbilled disbursements deductible under s. 9 A review of a law firm's accounts in 2005 revealed that accounts had been rendered in 2002, 2003 and 2004 which were uncollectible and which had not been written off. ...
TCC (summary)

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251 -- summary under Subsection 245(4)

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) limited scope of PUC provisions reflected a policy choice The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...
TCC (summary)

D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318 -- summary under Subsection 55(2)

D & D Livestock Ltd. v. The Queen, 2013 DTC 1251 [at at 1412], 2013 TCC 318-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) stock dividend by dividend payer did not reduce the safe income attributable to its subsidiary After a preliminary reorganization, all of the shares of the taxpayer (consisting of Class A common shares and Class D preference shares) were owned by another Canadian corporation ("HLL"), whose safe income on hand ("SIOH") respecting the taxpayer was $1.493M, comprised of safe income earned by the taxpayer of $0.976M and safe income of $0.517M in respect of the taxpayer's 50% shareholding of another Canadian corporation ("RTI"). ...

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