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Ralston & Co., 96 DTC 6488, [1996] 3 CTC 346 (FCTD)-- summary under Paragraph 256(1)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(a) 100 voting common shares of the taxpayer were held by members of the Cohen family, and the 100 voting preferred shares of the taxpayer were held as to 50 shares by the son of the Cohen's solicitor as to the other 50 preferred shares, by the solicitor's secretary. ...

Kibby & Anor., [1993] BTC 291 (D)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Vice-Chancellor Nicholls affirmed the finding of the Commissioner that the purchase as a going concern by the taxpayers of an existing fish and chip shop business in a village five miles away, followed by the continued conduct of that business from the same premises but with substantial variations in the mode of conduct thereof should be characterized as an expansion by the taxpayers of their own fish and chip business into the new premises, rather than as a continuation of the trade carried on by the former owner at the new premises. ...

Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)-- 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) The Ontario Development Corporation was a Crown agency within the meaning of s. 1 of the Crown Agency Act (Ontario) given that: the Crown owned all its shares; the Crown appointed all its directors, the permanent staff of the corporation were members of the public service; and the corporation was subject to the control of the Crown in the most fundamental aspects of its financial structure and operation. ...

Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)-- summary under Paragraph 256(1)(e) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(e) William Fast and his wife each owned 50% of the shares of one corporation ("Willmar"), and William Fast and his 4 siblings each owned 20% of the shares of the taxpayer. ...

Dupont Roofing & Sheet Metal Inc. v. Canada (National Revenue), 2011 DTC 5031 [at at 5614], 2011 FC 160-- summary under Subsection 223(3) Summary Under Tax Topics- Income Tax Act- Section 223- Subsection 223(3) In finding that the taxpayer's tax debt had been properly certified, Mosley J. found that the Minister had mailed the notice of assessment but went on to note, in the alternative, that a notice of assessment was not actually required. ...

Coopers & Lybrand Limitéé v. MNR, 94 D.T.C 1626, [1994] 2 CTC 2244 (TCC)-- summary under Remuneration Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(1)- Remuneration The appellant took possession on November 4, 1981 of the business of a debtor and, with the banks' authorization, paid the net amount of the employees' back wages pursuant to the usual payroll procedures of the debtor (including the preparation of payroll slips showing the deduction of source deductions). ...

Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense gratuitous bonus In respect of its 1969 and 1970 taxation years the taxpayer deducted management bonuses whose quantum was not ascertained until after the end of the taxation year and which, due in part to a reduction in the taxpayer's profitability, were not paid. ...

Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) Kerr, J. indicated, obiter, that s. 18(1)(e) would have applied to unpaid bonuses which the taxpayer sought to deduct: "When the decision to pay bonuses was taken in the fall of 1968 the amount that would be paid was uncertain, although a range of $25,000 to $30,000 was decided, and payment was contingent on necessary funds being available". ...

Muir Cap & Regalia Limited v. Minister of National Revenue, 91 DTC 533, [1991] 1 CTC 2342 (TCC)-- summary under Income of the Corporation for the Year From an Active Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Income of the Corporation for the Year From an Active Business The holding by the taxpayer of substantial term deposits for the future purchase of business premises was "only a collateral purpose... and the withdrawal of the fund would not have 'a decidedly destabilizing effect' on the taxpayer's operations" (p. 536). ...

Customs & Excise Commissioners v. Redrow Group plc, [1999] BTC 5062 (HL)-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient The Appellant, which was in the business of building new homes, offered to prospective buyers of its homes the services of real estate agents who would act in the sale of their existing homes, and had undertook to pay the agents' fees provided that the purchase of the new house from the Appellant went through. ...