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On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence parol evidence rule applied to Minister Campbell J. found that the parol evidence rule prevented the Minister from bringing extrinsic evidence that would have shown that the taxpayer was disingenuous in the way it characterized one of its business contracts for tax purposes. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income The taxpayer's business was to facilitate B.C. municipalities in obtaining vehicles and equipment. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) deduction of head office expenses The Canadian branch office of the taxpayer, which was a U.K. ...

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085, [1970] CTC 99 (FCTD)-- summary under Paragraph 110.1(1)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.1- Subsection 110.1(1)- Paragraph 110.1(1)(a) donations deductible as business expenses rather than as gifts Gifts which the taxpayer made to Jewish organizations in the Montreal area in amounts over $100 were accepted to have been made for the purpose of increasing its sales and, therefore were deductible in computing its income. ...

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085, [1970] CTC 99 (FCTD)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose donations deductible as business expenses rather than as gifts Gifts which the taxpayer made to Jewish organizations in the Montreal area in amounts over $100 were accepted to have been made for the purpose of increasing its sales and, therefore were deductible in computing its income. ...

Cunard & Company Limited v. Canada (Attorney General), 2012 DTC 5122 [at at 7192], 2012 FC 683-- summary under Subsection 85(7.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(7.1) not unreasonable to not permit late-filing by dissolved corporation Scott J. found that the Barnabe Estate principle, which allowed elections to be made by the estate of a deceased person, did not apply to a late-filed election by a corporation that had been wound up. ...

Baine, Johnstone & Co. Ltd., 77 DTC 5394, [1977] CTC 556 (FCTD)-- summary under Goodwill, Trademarks and Customer Lists Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership The Quebec taxpayer was found to have "acquired" trucks pursuant to leases given that it had possession and use of the trucks, it had assumed all risks, it had the option, six months before the expiry of the lease, to purchase the trucks for an amount approximately equal to the fair market value of the remaining lease payment, and it was required to pay the "rent" even if the trucks were destroyed or it no longer had the use of them. ...

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. ...