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A-Supreme Nursing & Home Care Services Inc. v. The King, 2023 TCC 39-- summary under Section 6 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 6 the provision of agency nurses to seniors’ homes qualified as exempt nursing services The appellant, in addition to providing nurses directly to individuals, placed nurses in the long-term care facilities and nursing homes of its Ontario clients and did not charge GST/HST on the related fees in reliance on the exemption for nursing services in Sched. ... Furthermore, although such Act “clearly puts the general responsibility of health care services on the operators of care homes” (para. 44), he considered (at para. 46) that: [T]he FCA’s decision [in HSC] should not be read to suggest that having general responsibility over the provision of health care services is a necessary condition to providing an exempt nursing services supply. … Finding otherwise would lead one to conclude that any service provided by a contractor is a supply of personnel rather than the service actually provided for. ...

Goar, Allison & Associates Inc. v. The Queen, 2009 DTC 653, 2009 TCC 174 (Informal Procedure)-- summary under Subsection 162(2.1) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(2.1) The taxpayer would not have been liable for a penalty under s. 162(1) because it had no income. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Campbell J. rejected a submission of the Crown that leases acquired by the taxpayer had a nil cost to it because their acquisition was financed by the third party to whom it then disposed of the leases in satisfaction of the financing. ...

James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC)-- summary under Paragraph 7000(1)(d) Summary Under Tax Topics- Income Tax Regulations- Regulation 7000- Subsection 7000(1)- Paragraph 7000(1)(d) Pawners were under no obligation to repay sums paid to them by a pawnbroker unless they redeemed the articles in question. ...

Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC)-- summary under Subsection 153(1.3) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.3) Sobier TCJ. accepted a submission that an interim receiver was acting only as a watchman or conservator, and could not make business decisions. ...

Hewitt & Sons Ltd. v. The Queen, 2000 DTC 2441 (TCC)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) Interest on a loan made by the taxpayer to a foreign affiliate was includable in its income at the 5% interest rate provided in the loan agreement notwithstanding that such interest was not received by the taxpayer. ...

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. ...

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. ...

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. ...

Matt Harris & Son Ltd. v. The Queen, 2001 DTC 28 (TCC) (Informal Procedure)-- 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 taxpayer, the operator of a wood contracting and construction business, was able to deduct the amount of racing expenses incurred by it (less prize money claimed) in respect of a stock car owned by it but driven by its sole shareholder and president, on the basis that such expenses were a form of advertising, and should not be disallowed simply because of the owner's satisfaction and interest in the activity. ...