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Laurent Goulet & Fils Inc. v. MNR, 92 DTC 1611 (TCC)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property At the time the taxpayer contacted the lessor ("Hewitt") of equipment to it that it wished to exercise the purchase option, Hewitt suggested another institution ("Lafleur") as a source of financing the purchase. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus At the time of reassessing the taxpayer, Revenue Canada indicated that it regarded the taxpayer's interest in a property as having been acquired in exchange for services to be provided by the taxpayer. ...

Vancouver A & W Drive-Ins Ltd. v. United Food Services Ltd. (1981), 13 BLR 89 (BCSC)-- summary under Paragraph 146(2)(a) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(a) It was stated in response to an argument that the Act operates to deprive an annuitant of his right to terminate an R.R.S.P. trust: "It is one thing to say you cannot have a plan which provides for payment of benefits before maturity- which is what s. 146(2)(a)(i)(A) says. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure 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. ...

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. ...

Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Ten percent of all payments due to contractors by the taxpayer for various capital improvements were not payable by it until the contracts have been substantially completed to the satisfaction of the supervising engineer, and all the claims of sub-contractors and employees have been met by the contractors. ...

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"). ...

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc., 94 DTC 6541, [1994] 2 CTC 336 (FCA)-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 An operation of repairing and "re-manufacturing" hydraulic systems for customers (including the replacement of a part or parts of a customer's hydraulic system with the part or parts manufactured by the taxpayer) was found not to be the manufacturing of goods "for sale" on the basis of the "well-known distinction between manufacturing for the purpose of sale and manufacturing for the purpose of repair services", and in light of Parliament's objective in enacting the legislation, which "was encouragement of increased production of manufactured and processed goods to be placed on the domestic and international markets in competition with foreign manufacturers" (p. 6548). ...

Carlson & Associates Advertising Ltd. v. The Queen, [1997] GSTC 32 (TCC), briefly aff'd [1998] GSTC 25 (FCA)-- summary under Paragraph 296(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1)- Paragraph 296(1)(b) only potential for double taxation The appellant ("Carlson Advertising"), on running into financial difficulties, did not pay GST to suppliers. ...