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Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)-- summary under Subsection 5903(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903- Subsection 5903(3) A U.S. resident corporation ("Trans World U.S. ...

Bank & Trust Co. v. Eelman (1936), 183 Atlantic Reporter 677, 116 N.J. 279 (Sup Ct of NJ)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract In satisfaction of a prior judgment against the defendant, the plaintiff sought an order for garnishment of the monthly pension of the defendant, who was a retired police officer. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) manufacturing trade exercised in UK notwithstanding place of distributorship contracts tThe taxpayer ("Brentford"), which was a U.K. subsidiary of a U.S. corporation ("Akron") manufactured tires for sale, as agent for Akron, to distributors of Akron located in various countries including Sweden. ...

Rowe & Maw v. Customs and Excise Commissioners, [1975] 2 All E.R. 444 (Q.B.D.)-- summary under Section 178 Summary Under Tax Topics- Excise Tax Act- Section 178 In finding that charges of a firm of solicitors for reimbursement of their railway and air fares constituted, on general principles, part of the consideration for the services provided by them to their clients, Bridge J. stated (p. 448): "On the one hand a solicitor (like any other agent) may purchase goods or services for its client, as for instance when paying stamp duty, court fees, or buying, say, a travel ticket to enable the client to travel. ...

Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA)-- summary under Canadian Investment Income Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Canadian Investment Income funds employed and risked in the business were used in the business Interest earned, on the investment of funds received by an insurance broker, during the period before those funds had to be paid to the insurers, was held not to be Canadian investment income under the pre-1979 version of the definition. ...

Roman Miniotas (Romeo’s Plumbing & Heating) v. The Queen, 2011 DTC 1078 [at at 420], 2011 TCC 43-- summary under Subsection 167(5) Summary Under Tax Topics- Income Tax Act- Section 167- Subsection 167(5) The taxpayer's accountant sent letters on 3 and 24 October 2007, appealing an assessment. ...

Lewis & Son Ltd. v. Kerman, [1970] 3 All ER 414 (CA)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.24(2)(g) of the Agricultural Holdings Act 1948 (U.K.) gave a landlord of an agricultural holding, such as the plaintiff, the right to determine the tenancy within three months of the death of the tenant with whom the contract of tenancy was made. ...

Morgan Stanley & Co International PLC, [2015] UKSC 12-- summary under Subsection 12(3) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(3) "accrue" describes the coming into being of a right or obligation Lord Reed stated (at para. 41): The word "accrue" is generally used to describe the coming into being of a right or an obligation (as, for example, in Aitken v South Hams District Council [1995] 1 AC 262), so that the person in question then has an accrued right, or is subject to an accrued liability, as the case may be. ...

Panther Oil & Grease Manufacturing Co. of Canada Ltd., 61 DTC 1222, [1961] CTC 363 (Ex Ct)-- summary under Subsection 400(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 400- Subsection 400(2) The taxpayer, whose factory in Ontario filled orders for roofing materials and lubricants generated by its sales force in various provinces, including Quebec, was found to have a "branch" in Quebec (notwithstanding that its large sales force there used their own homes) because "it had a component portion of its sales organization there" (p. 1230), and also had an "agency" in Quebec because its Quebec division manager and district managers "were its instrumentalities for the conduct of its sales in Quebec" (p. 1230). ...

Cancer Relief & Research Institute, [1939] 4 DLR 191 (Man. K.B.)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation corporation has separate legal personality In finding that an institute which section 2 of the Cancer Relief Act, 1930 (Manitoba) purported to make a "body corporate" was not, in fact, a corporation because there were no natural persons to compose or to constitute the corporation, Dysart J. stated (pp. 193-194): "What is a corporation? ...