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Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange for the right to salvage the wreckage), but the obligation only triggered when the respondent gave the appellant possession of the building to be demolished. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 212(1)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(a) The taxpayer, which was the portfolio manager of the Cundill Value Fund and the Cundill Security Fund (the "Funds"), contracted with a Bermuda company ("PCAB") for the investment counselling and transaction skills of F. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) dependency on name fund manager and 50% owner The taxpayer, which was the portfolio manager for the Cundill Value Fund and the Cundill Security Fund was dependent upon Mr. ...

Bairstow & Harrison, (1955), 36 TC 207, [1955] UKHL TC (HL)-- summary under Machinery and Equipment Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)-- summary under Paragraph 256(1)(b) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(b) ignore voting agreements A corporation ("Burland") was owned by nine children of four fathers. ...

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) required transfer of value between subs not a benefit One company in a group of UK companies (the "Lender") made a loan to a subsidiary (the "Borrower"). ...

Laurent Goulet & Fils Inc. v. MNR, 92 DTC 1611 (TCC)-- summary under Qualified Property Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Qualified 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. ...

Peter Dixon & Son Ltd. (1943), 25 TC 353 (CA)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The Finnish subsidiary of the taxpayer arranged to repay shareholder advances of £319,600 by issuing notes with a face amount of £340,000 and bearing interest at 1% over the Bank of Finland discount rate. ...

Minister of Customs & Excise, [1928] S.C.R. 54-- summary under Similar Statutes/ in pari materia Summary Under Tax Topics- Statutory Interpretation- Similar Statutes/ in pari materia Customs Tariff Schedule established that “nursery stock” in Special War Revenue Act, 1915 only referred to trees, plants and shrubs and not potted plants In the course of finding that sales by florists of potted plants were not exempted from the sales tax imposed by s. 19BBB of the Special War Revenue Act, 1915 as being sales of "nursery stock," Duff C.J., stated: As to potted plants—"nursery" implies a place devoted to the cultivation of trees, shrubs, and plants—for the purpose of transplantation; bringing them to a degree of maturity in which that is practicable. ...

Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 whether partnership exists while only preliminary partners Arden LJ followed Eclipse in finding that a film tax shelter partnership was not carrying on a trade given that the film it acquired was immediately leased out for a stream of licensing payments which matched its debt servicing commitments- so that in essence its business was “the payment of a lump sum in return for a series of fixed payments over 15 years.” ...