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Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property not yet depreciable property if not usable At the request of the taxpayer, the vendor of equipment purported to pass title in the equipment to the taxpayer in its 1979 taxation year. ...

& E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.)-- summary under Subsection 341(1) Summary Under Tax Topics- Excise Tax Act- Section 341- Subsection 341(1) In response to the proposed repeal effective 1 June 1984 of the zero rating of building alteration services, four building companies with existing contracts for building alterations arranged with their customers for payment by the customers before that date subject (in one case) to the condition that the building company would immediately lend back an equivalent sum, to be repaid as the work was done or subject (in the other case) to that money being paid into an account of the building company for release only as the work was done. ...

P & O (Dover) Ltd. v. Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient employer the recipient of criminal counsel services The appellant along with seven individual employees was charged with manslaughter in connection with the sinking of its vessel. ...

Burns Sand & Gravel v. MNR, 68 DTC 226 (TAB)-- summary under Proceeds of Disposition Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition The taxpayer agreed to rent five acres of land for a period of three years at a rent of $1,600 per annum, and provided the lessee with the option of purchasing the land at any time before the expiry of the lease for a price of $16,000 minus 90% of all rentals previously paid. ...

Hanger & Co., Ltd., [1936] 1 All ER 535 (QBD)-- summary under Patents and Know-How Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business The sole shareholder ("Ross") of the taxpayer served as the CFO of a Canadian company ("Clearly Canadian") and also performed services on behalf of the taxpayer for Clearly Canadian. ...

London & Quadrant Housing Trust, [1999] 3 WLR 150 (HL)-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex licensee granted tenancy A housing trust that had been granted a licence by the local authority to use a number of properties for redevelopment as temporary accommodation for homeless persons and which signed an agreement with the plaintiff for occupation of a self-contained flat in one of the properties on a temporary basis on a weekly licence was found to have thereby created a tenancy in favour of the plaintiff because the agreement with the plaintiff had all the characteristics of a tenancy, including the grant of exclusive possession. ...

Pizzolati & Chittaro Manufacturing Co. Ltd. v. May et al., [1971] 3 OR 768 (Ont HCJ)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract One defendant sold his business to the other. ...

Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Before finding that the taxpayer was permitted to deduct expenses which it incurred in opposing a nationalization of its business that would have entailed a successor entity acquiring its assets in continuing to carry on its trade, Lord Reid stated (p. 57): It is not difficult to suppose a case where a trader is shortly to be succeeded in his trade by another person and where he spends money the benefit of which will accrue in whole or in part to his successor. ...

Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees A company engaged in a sugar refining business was entitled to deduct expenses of propaganda campaign directed against the nationalization of the sugar refining business, on the basis that such expenses were "wholly and exclusively laid out or expended for the purposes of the trade" within the meaning of rule 3(a) of the Rules applicable to Schedule D, Cases I and II. ...