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& E. Commrs v. Bell Concord Educational Trust Ltd., [1989] BTC 5061 (C.A.)-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) An incorporated college which, in fixing the student fees, budgeted for a substantial surplus of revenues over expenditure to be applied in maintaining and improving the school's facilities, was providing education "otherwise than for profit" because the surplus could never redound for the profit of any member but must instead be applied for the charitable purposes of the company. ...

Les Placements A & N Robitaille Inc. v. MNR, 96 DTC 1062, [1996] 1 CTC 2141 (TCC)-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other In determining the fair market value of the goodwill of a business of reconditioning and selling boats and other nautical products, Archambault TCJ. applied a relatively low capitalization rate of 4.0 to normalized earnings in light of the yield on long-term federal government bonds of 9.5%, the competitive nature of the business, the risk of expropriation of the premises occupied by the business, and the lack of expertise on the part of the staff. ...

Dew Engineering & Development Ltd. v. The Queen, 96 DTC 1765 (TCC)-- summary under Subsection 37(8) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(8) A portable laboratory composed of five modules connected to one another by bolts (and that were almost identical to the components of the walkways used at the Ottawa International Airport) was found (at p. 1770) not to be a building given that it was "not installed and intended to remain in a particular location". ...

Deeny & Ors v. Gooda Walker Ltd., [1995] BTC 470 (CA)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Damages received by Lloyd's names pursuant to their action against agents (who were member's agents) for their failure to exercise reasonable skill and care in conducting the business of underwriting on behalf of the names, were taxable as being received in respect of a trade carried on in the U.K. ...

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280-- summary under Subsection 168(9) Summary Under Tax Topics- Excise Tax Act- Section 168- Subsection 168(9) meaning of deposit adopted Wong J quoted with approval the comments in T endances et Concepts as to what was a deposit, but then found that, given the lack of probative documentary evidence provided by the taxpayer, none of the amounts assessed by the Minister had been established to be deposits. ...

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. ...

& E. Cmners, [1988] BTC 5160 (Q.B.D.)-- summary under Subparagraph 8(1)(i)(i) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(i) leisure and amenity management was not a profession The members of a non-profit organization formed to provide a central organization for persons described as engaged in the "profession" of leisure and amenity management, were not practising a "profession". ...

Keir & Cawder, Ltd. v. C.I.R. (1958), 38 TC 23 (C.S. (1st Div.))-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) The taxpayer, which sold materials for use in construction projects, made a foray into the field of construction contracting which was terminated on the death of a consulting engineer whose services it had retained. ...

Keir & Cawder, Ltd. v. C.I.R. (1958), 38 TC 23 (C.S. (1st Div.))-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, whose main activity was carrying on the trade of quarrymasters, sought to extend its business to civil engineering contracting by retaining a firm of consulting engineers to provide the services and reputation of one of their engineers. ...

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Before finding that a clause in a lease giving the lessee the unilateral right to compel the lessor to sell helicopters to the lessee at their reasonable fair market value was an "option", Major J. stated his agreement with the following list of the three principal features of an option: exclusivity and irrevocability of the offer to sell within the time period specified in the option; specification of how the contract of sale may be created by the optionholder; and obligation of the parties to enter into a contract of sale if the option is exercised. ...