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James Snook & Co., Ltd. v. Blasdale (1952), 33 T.C. 244 (CA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The agreement for the sale of the shares in the capital of the taxpayer provided that the purchaser would cause the taxpayer to pay compensation for loss of office to directors of the taxpayer. ...

Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence Mr. ...

Parsons & Steiner v. MNR, 62 DTC 1148 (Ex Ct)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments capital receipt for cancellation of distributorship Compensation received by the taxpayer, which carried on the business of a manufacturer's agent and wholesale merchant in china and related wares, for the cancellation, after 18 years, of its agency arrangement for the distribution on commission of Doulton china in Canada, was a capital receipt. ...

Wattie & Anor., [1998] BTC 438 (PC)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business Before going on to find that a lump sum received by an accounting firm in consideration for entering into a lease of office premises was a capital receipt, Lord Nolan stated (at p. 446) that: "The crucial question is whether in all the circumstances, the payment or receipt can properly be attributed to a particular year. ...

Wattie & Anor., [1998] BTC 438 (PC)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement Before going on to find that a lump sum received by an accounting firm in consideration for entering into a lease of office premises was a capital receipt, Lord Nolan stated (at p. 446) that: "The crucial question is whether in all the circumstances, the payment or receipt can properly be attributed to a particular year. ...

& C. Ltd. (1983), 148 DLR (3d) 348 (N.S. C.A.)-- summary under Subparagraph 212(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(b)- Subparagraph 212(1)(b)(ii) Sydney Steel Corporation was not an agent of the Crown given that in controlling the day-to-day operations of its plant it was operating independently, and notwithstanding that its directors and officers were appointed by the Crown. ...

Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506, [1996] 2 CTC 2426 (TCC)-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits The production of asphalt for use in the paving of driveways, parking lots and small public roadways was found not to qualify as use for contracts for sale, rather than contracts for work and materials. ...

Minister of Municipal Affairs of the Province of New Brunswick (1986), * A.P.R. ...

Akman & Sons (Fla) Inc. v. Chipman (1987), 38 BLR 185 (Man QB)-- summary under Subsection 98(1) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(1) A real estate development partnership was terminated by the statement of the plaintiff that it wished to terminate the partnership and that it would not be paying its share of a balloon payment coming due on a mortgage secured on the partnership property, notwithstanding that a termination agreement was not concluded until later. ...

& Ors. v. The Commissioners of Income Tax, [1985] BTC 550 (PC)-- summary under Retroactivity/Retrospectivity Summary Under Tax Topics- Statutory Interpretation- Retroactivity/Retrospectivity "While it is always open to a sovereign Parliament to change tax rules for the future, and even to do so retrospectively provided that the requisite intention is made clear, one intention not readily to be attributed to the legislature is that of disturbing legitimate expectations upon the faith of which development companies had earlier made irrevocable elections not to claim initial allowances. ...