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Coopers & Lybrand Ltd. v. Bank of Montreal, [1993] GSTC 36 (Nfld. ...

Javalin Founderies & Machine Works Ltd. v. MNR, 67 DTC 392 (TAB)-- summary under Subsection 69(4) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(4) In finding that a transaction under which the individual non-resident shareholder of a Canadian corporation took possession of all its assets after the corporation ceased to carry on business transactions subject to s. 17(5), the Board noted (at p. 398) that "if the purpose of section 17... is to prevent companies from understating their income by distributing stock-in-trade to shareholders either as gifts or upon winding-up without ascribing any value thereto in terms of payment by the shareholder", whereas here the shareholder had taken possession of capital assets. ...

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 "S.231(3) is only available to the Minister to obtain information relevant to the tax liability of some specific person or group of persons if the tax liability of such person or persons is the subject of a genuine and serious inquiry. ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC)-- summary under Active Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Active Business Interest income which the corporate taxpayer, which was in the business of selling and servicing equipment used in the mining industry, earned on term deposits was held to be active business income. ...

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. ...

Rowntree & Co. Ltd., [1948] 1 All ER 482 (CA)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer drew sight bills on an acceptance house which, after accepting the bills, discounted them in the market as agent for the taxpayer and remitted the proceeds to the taxpayer. ...

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. ...

Kibby & Anor., [1993] BTC 291 (D)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Vice-Chancellor Nicholls affirmed the finding of the Commissioner that the purchase as a going concern by the taxpayers of an existing fish and chip shop business in a village five miles away, followed by the continued conduct of that business from the same premises but with substantial variations in the mode of conduct thereof should be characterized as an expansion by the taxpayers of their own fish and chip business into the new premises, rather than as a continuation of the trade carried on by the former owner at the new premises. ...

Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)-- summary under Subparagraph 212(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(b)- Subparagraph 212(1)(b)(ii) The Ontario Development Corporation was a Crown agency within the meaning of s. 1 of the Crown Agency Act (Ontario) given that: the Crown owned all its shares; the Crown appointed all its directors, the permanent staff of the corporation were members of the public service; and the corporation was subject to the control of the Crown in the most fundamental aspects of its financial structure and operation. ...