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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. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Scheme Summary Under Tax Topics- Statutory Interpretation- Scheme Since s. 20(1)(c) was thought to be almost a mirror image of s. 12(1)(e), case law as to the meaning of the latter was found to be relevant to the meaning of the former. ...

Canada and Coopers & Lybrand Ltd., 86 DTC 6243 (BCSC)-- summary under Subsection 227(9) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9) A penalty for failure to remit employee source deductions on the due date of February 15, 1985 was not a claim provable in bankruptcy because the proposal under the Bankruptcy Act was filed on February 6, 1985. ...

Johnson & Johnson Inc. v. D.MNR, 88 DTC 6235, [1988] 2CTC 1 (FCTD)-- summary under Interpretation Bulletins, etc. ...

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. ...

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Specific v. ...

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. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Interpretation Bulletins, etc. ...

Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)-- summary under Subsection 45(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 45(2) A comparison of s. 256(1)(e) with s. 39(4) of the pre-1972 Act helped establish that in s. 256(1)(e) Parliament intended that the shareholding of one member of a group was insufficient to fulfill the cross-shareholding requirement in s. 256(1)(e). ...

McMaster University / In re Porto Rico Power Co., [1946] S.C.R. 178, [1946] 2 DLR 81-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Accrued but unpaid dividends were not a debt because there was no guarantee of payment. ...