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Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership The Quebec taxpayer was found to have "acquired" trucks pursuant to leases given that it had possession and use of the trucks, it had assumed all risks, it had the option, six months before the expiry of the lease, to purchase the trucks for an amount approximately equal to the fair market value of the remaining lease payment, and it was required to pay the "rent" even if the trucks were destroyed or it no longer had the use of them. ...

Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Before finding that the taxpayer was permitted to deduct expenses which it incurred in opposing a nationalization of its business that would have entailed a successor entity acquiring its assets in continuing to carry on its trade, Lord Reid stated (p. 57): It is not difficult to suppose a case where a trader is shortly to be succeeded in his trade by another person and where he spends money the benefit of which will accrue in whole or in part to his successor. ...

Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees A company engaged in a sugar refining business was entitled to deduct expenses of propaganda campaign directed against the nationalization of the sugar refining business, on the basis that such expenses were "wholly and exclusively laid out or expended for the purposes of the trade" within the meaning of rule 3(a) of the Rules applicable to Schedule D, Cases I and II. ...

Abakhan & Associates Inc. v. Canada (Attorney General), 2008 DTC 6028, 2007 FC 1327-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) insufficient evidence of misrepresentation O'Reilly J. indicated that he saw nothing preventing a company from making a request for judicial review of a decision of the Minister not to accede to the corporation's request for a reassessment of a taxation year (preceding the normal reassessment period) in which the taxpayer allegedly had exaggerated its own taxable income. ...

Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB)-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) "real purpose" of agreement was right to use trademark The taxpayer, which was a Canadian manufacturer of ladies' dresses, agreed in writing with a U.S. company that it would have the exclusive Canadian rights in respect of the "Anne Klein" line of clothing in consideration for the payment of $6,500 per year plus 3% of its annual sales in respect of that line in excess of $150,000. ...

Oriole Oil & Gas Ltd. v. The Queen, 91 DTC 5143 (FCTD)-- summary under Paragraph 18(1)(a) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a) After the two shareholders and principals of a private company decided to seek a purchaser for their shares, they entered into a contract with their company which provided for the payment of an annual salary to each of them for an extended period of time, and the payment of a "bonus" of 7 1/2% of the asset value of the company if there were to be a sale of the company's assets before the employee attained the age of 55. ...

Longmans Green & Co., Ltd. (1932), 17 TC 272 (K.B.D.)-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) The respondent agreed with the French author of a book that it would acquire the exclusive right of translation and publication in the English language of the book. ...

Alexander Von Glehn & Co. Ltd. (1920), 12 T.C. 233 (CA)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The taxpayer was unable to deduct penalties which it agreed to pay to the Attorney-General as a result of being unable to establish that goods which it exported from Britain during the First World War to neutral countries would not be used by the enemy, and also was unable to deduct related legal fees. ...

Customs & Excise Commissioners, [2002] BTC 5280 (Court in Session (Inner House))-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient The Appellant, which was entitled to issue its own bank notes, entered into a reciprocal agreement with other banks pursuant to which it was entitled to a flat fee per transaction when customers of the other banks were issued bank notes of the Appellant (or bank notes of the Bank of England) through ATMs of the Appellant. ...

Simmonds & Sons Ltd. v. MNR, 89 DTC 707, [1990] 1 CTC 2087 (TCC)-- summary under Subsection 17(1) Summary Under Tax Topics- Income Tax Act- Section 17- Subsection 17(1) Because a U.S. affiliate ("Dynacharge U.S. ...