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Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "we will then advance all postage charges to Royal Mail on your behalf. ...

Customs & Excise Commissioners v. Plantiflor Ltd., [2002] UKHL 33, [2002] 1 WLR 2287, [2002] STC 1132', [2002] BTC 5413 (HL)-- summary under Subsection 165(1) Summary Under Tax Topics- Excise Tax Act- Section 165- Subsection 165(1) The taxpayer, which sold horticultural products by mail order, indicated in its catalogue that customers would pay an additional charge to cover the costs of postage and packing, and stated "We will then advance all postage charges to Royal Mail on your behalf. ...

John Dry Dock & Shipbuilding Co. v. MNR (1944), 2 DTC 663 (Ex Ct)-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) government construction subsidy not received in the course of business Before concluding that a subsidy received by the taxpayer from the federal government, pursuant to a statute, for the construction of a dry dock was a capital receipt, Thorson P. indicated that (at p. 669-670): "The appellant was not entitled to receive nor did receive the subsidy in the course of its trade or business operations or because of them.... ...

Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property not yet depreciable property if not usable At the request of the taxpayer, the vendor of equipment purported to pass title in the equipment to the taxpayer in its 1979 taxation year. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius reference to person implied exclusion of persons In finding that reference to control by a person did not include control by persons, Cartwright J. stated (pp. 1192-1193): "When section 127 by clause (b) provides that corporations controlled directly or indirectly by the same person shall be deemed not to deal with each other at arm's length it appears to me to negative the view that corporations are to be deemed not to deal with each other at arm's length when controlled not by the same person but by the same group of persons. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Subsection 33(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 33(2) In finding that reference to control by a person did not include control by persons, Cartwright J. stated (pp. 1192-1193): "When section 127 by clause (b) provides that corporations controlled directly or indirectly by the same person shall be deemed not to deal with each other at arm's length it appears to me to negative the view that corporations are to be deemed not to deal with each other at arm's length when controlled not by the same person but by the same group of persons. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership the shares of a subsidiary of a corporation are not owned “indirectly” by the shareholders of that corporation Whether a corporation (the Western Company) was related to its two equal corporate shareholders (the Alberta Company and the Saskatchewan Company) under s.36(4)(b)(iii) of the 1948 Act turned, in part, on whether the related individuals owning all the shares of the Alberta Company and the Saskatchewan Company were to be considered as “owning] directly or indirectly” the shares of the Western Company. ...

Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base The taxpayer agreed to transfer its Toronto property to the City of Toronto with the compensation to be determined (under section 31 of the Expropriations Act) by the Ontario Municipal Board. ...

& E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.)-- summary under Subsection 341(1) Summary Under Tax Topics- Excise Tax Act- Section 341- Subsection 341(1) In response to the proposed repeal effective 1 June 1984 of the zero rating of building alteration services, four building companies with existing contracts for building alterations arranged with their customers for payment by the customers before that date subject (in one case) to the condition that the building company would immediately lend back an equivalent sum, to be repaid as the work was done or subject (in the other case) to that money being paid into an account of the building company for release only as the work was done. ...

The Humber College Institute of Technology & Advanced Learning v. ...