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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. ...

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. ...

Goodyear Tire & Rubber Co. of Canada Ltd. et al. v. T. Eaton Co. ...

John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 lump sum for indefinite right to use property not a royalty Thurlow, C.J. stated (p. 6275) that "'royalties'... connotes a payment calculated by reference to the use or to the production or revenue or profits from the use of the rights granted" and that "neither 'rentals' nor 'royalties', in the ordinary connotation... includes a lump sum payment for the use of or for the privilege of using property indefinitely. ...

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. ...

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) Insurance premiums were payable each year by the taxpayer pursuant to a Lloyds policy which established the premiums payable for each year in accordance with a formula which included "reserves, as estimated by the Insurers for outstanding losses, outstanding at the time of adjustment. ...

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. ...