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Young, Austen & Young Ltd., [1989] BTC 77 (C.A.)-- summary under Subsection 86(1) Summary Under Tax Topics- Income Tax Act- Section 86- Subsection 86(1) In finding that an issuance of shares by a company to its existing beneficial shareholder, followed by the application of the subscription proceeds to pay off intercompany indebtedness, was a "reorganization... of a company's share capital" on ordinary principles, Balcombe L.J. stated: "an increase of share capital can be a reorganization of that capital... provided that the new shares are acquired by existing shareholders because they are existing shareholders and in proportion to their existing beneficial holdings. ...

Weiss, Biheller & Brooks, Ltd. v. Farmer (1922), 8 TC 381 (CA)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) agent distributor The taxpayer, which was an English company carrying on business as an importer and merchant, and which was the exclusive distributor of gas mantles manufactured by a Dutch company, was found to have been properly assessed as agent for the Dutch company in respect of profits derived by the Dutch company in carrying on a trade within the United Kingdom as vendor of the gas mantles, notwithstanding that there was no privity of contract between the English customers and the Dutch company, and that property in the mantles may have passed to the taxpayer. ...

& E. Cmners. v. West Yorkshire Hospital (Contract Services) Ltd., [1988] BTC 5095 (Q.B.D.)-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning "First, while (the context apart) one would expect payment to be construed in its ordinary sense, it is a well recognized legal concept. ...

Bowes & Cocks Ltd. v. MNR, 89 DTC 341, [1989] 2 CTC 2043 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer used borrowed money to acquire additional shares of its subsidiary, which the taxpayer immediately wound-up in the process of which a piece of rural land (the subsidiary's only significant asset) was conveyed to the taxpayer. ...

& J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing The taxpayer was unsuccessful in deferring the recognition of income under contracts relating to the installation of manufacturing equipment to the year of completion of the contracts, rather than the time of receipt of amounts under the contracts, given that the amounts received were not subject to any restrictions as to disposition, use for enjoyment. ...

Richter & Associates Inc v. The Queen, 2005 TCC 92-- summary under Subsection 141.01(5) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(5) allocation between own suit and litigation support The allocation of substantially all the litigation-related costs of a trustee in bankruptcy to its "litigation support business" of supporting of a negligence suit for $800 million brought by the bankrupt company's creditors against the company's former auditors rather than to its action on behalf of the estate for $40 million for breach of contract, was found to be "fair and reasonable" in compliance with s. 141.01(5). ...

Deloitte, Haskins & Sells Ltd, Trustee of Pheonix v. Bank of Nova Scotia, 89 DTC 5355, [1989] 1 CTC 442 (Sask. ...

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning word sale should be accorded its private law meaning Major J. indicated (ca. para. 30) that in providing an incentive for equipment that was used in Canada primarily in the manufacturing or processing of goods "for sale or lease", "Parliament has chosen to use language that imports relatively fine private law distinctions", and that "the technical nature of the Act does not lend itself to broadening the principle of plain meaning to embrace popular meaning. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Accounting Principles Summary Under Tax Topics- General Concepts- Accounting Principles Before finding that both ss.20(1)(c) and 12(1)(c) "require accounting in conformity with ordinary commercial practices and/or generally accepted accounting principles" (p. 6188) Reed J. stated (p. 6186): "A distinction must be made between a requirement that income for tax purposes be accounted for generally in conformity with accounting principles and a requirement that the taxpayer's treatment of his financial statements and his tax returns be identical. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) It was stated, obiter, that s. ...