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Smidth & Co. v. F. Greenwood (1921), 8 TC 200 (CA), aff'd 206 (HL)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) mere installation in jurisdiction The taxpayer, which manufactured cement-making equipment in Denmark, delivered the machinery F.O.B. at Copenhagen, and concluded the sales contracts in Denmark was found not be exercising a trade in the United Kingdom notwithstanding the maintaining of a sales office in London where a full-time employee inspected the site of proposed installations, forwarded samples to Denmark for testing, and superintended installations of the machinery. ...

Young, Austen & Young Ltd., [1987] BTC 530 (HCJ), rev'd [1989] BTC 77 (C.A.)-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions "includes means a wide range of things "[T]he word 'include' may be used in such a definition to enlarge the natural meaning of the word defined, or to clarify it, or to introduce examples of its meaning, or to introduce restrictions on that meaning, or for two or more of those purposes. ...

Wampole & Co. Ltd., [1931] S.C.R. 494-- summary under Double Taxation/Deduction (Presumption Against) Summary Under Tax Topics- Statutory Interpretation- Double Taxation/Deduction (Presumption Against) no intention to impose sales tax twice on manufacturer S. 87(d) of the Special War Revenue Act, imposed tax on goods which were “for use by the manufacturer or producer and not for sale,” was found to apply to the distribution by a pharmaceutical manufacturer of drug samples to doctors, but for the fact that the samples had already been subject to tax in the hands of the manufacturer. ...

Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Certainty Summary Under Tax Topics- Statutory Interpretation- Certainty preferred interpretation should meet a minimum level of cetainty In finding that a federal sales tax refund should not be considered to have been receivable by the taxpayer until the Minister had given some public irrevocable indication thereof, Hugessen J.A. stated (p. 6128): "The decision creates rights and starts time running and it is as much in the public interest as in that of those immediately concerned that there be a basic minimum of certainty as to when it is made and what it is. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- Section 103- Subsection 103(1) "salary" to partner is a profits distribution In discussing the nature of a partnership, Lord Oliver stated (p. 900): "A partner working in the business or undertaking of the partnership is in a very different position from an employee... ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Paragraph 96(1)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(a) Lord Oliver rejected a finding of the Court of Appeal that a firm of accountants could be regarded as a "notionally distinct entity" in order to assess the purpose of expenditures incurred by it in reimbursing the relocation expenses of its partners. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Paragraph 96(1)(f) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(f) "salary" to partner is part of profits division Lord Oliver stated (p. 589) that "if, with the agreement of his partners, [a partner] pays himself a 'salary', this merely means that he receives an additional part of the profits before they fall to be divided between the partners in the appropriate proportions. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 partner salary is a draw In discussing the nature of a partnership, Lord Oliver stated (p. 900): A partner working in the business or undertaking of the partnership is in a very different position from an employee... ...

Johnson & Johnson Inc. v. The Queen, 92 DTC 6373, [1992] 2 CTC 86 (FCTD), aff'd on other grounds 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business A federal sales tax refund was taxable income given that the receipt was linked to the taxpayer's income-earning process (the price at which the taxpayer sold its products included the federal sales tax, although the taxpayer felt it had no responsibility to pass on the amount of the refund to its customers). ...

Johnson & Johnson Inc. v. The Queen, 92 DTC 6373, [1992] 2 CTC 86 (FCTD), aff'd on other grounds 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement A federal sales tax refund was taxable income given that the receipt was linked to the taxpayer's income-earning process (the price at which the taxpayer sold its products included the federal sales tax, although the taxpayer felt it had no responsibility to pass on the amount of the refund to its customers). ...