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Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166, [1990] 1 CTC 229 (FCA)-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Ten percent of all payments due to contractors by the taxpayer for various capital improvements were not payable by it until the contracts have been substantially completed to the satisfaction of the supervising engineer, and all the claims of sub-contractors and employees have been met by the contractors. ...

Hewitt & Sons Ltd. v. The Queen, 2000 DTC 2441 (TCC)-- summary under Subsidiary Controlled Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Subsidiary Controlled Corporation 40%f the shares of a Bahamian affiliate ("Bahamas") of the taxpayer were owned by the taxpayer and 60% of the shares of Bahamas were owned by another Bahamian corporation ("Abaco"). ...

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc., 94 DTC 6541, [1994] 2 CTC 336 (FCA)-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 An operation of repairing and "re-manufacturing" hydraulic systems for customers (including the replacement of a part or parts of a customer's hydraulic system with the part or parts manufactured by the taxpayer) was found not to be the manufacturing of goods "for sale" on the basis of the "well-known distinction between manufacturing for the purpose of sale and manufacturing for the purpose of repair services", and in light of Parliament's objective in enacting the legislation, which "was encouragement of increased production of manufactured and processed goods to be placed on the domestic and international markets in competition with foreign manufacturers" (p. 6548). ...

Carlson & Associates Advertising Ltd. v. The Queen, [1997] GSTC 32 (TCC), briefly aff'd [1998] GSTC 25 (FCA)-- summary under Paragraph 296(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1)- Paragraph 296(1)(b) only potential for double taxation The appellant ("Carlson Advertising"), on running into financial difficulties, did not pay GST to suppliers. ...

Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180, [1989] 1 CTC 417 (FCTD)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Deloitte & Touche, 128 OR (3d) 225, 2016 ONCA 11, rev'd in part 2017 SCC 63-- summary under Illegality Summary Under Tax Topics- General Concepts- Illegality auditors liable for failure to detect the company’s own fraud effected through its senior management Deloitte was unsuccessful in arguing that it was not liable to the receiver for a public company (Livent), for failure to detect the fraudulent misstatement of Livent’s financial statements, because it was the most senior management of Livent who were proactively engaged in the fraud, so that effectively Livent was suing Deloitte for Livent’s own fraud. ...

Wampole & Co. Ltd., [1931] S.C.R. 494-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) “use” includes providing free samples 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. ...

Samarkand Film Partnership No. 3 & Ors v Revenue and Customs, [2017] EWCA Civ 77-- summary under Paragraph 96(1)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(a) rent received qua landlord rather than partner In rejecting an argument that the determination of whether a partnership carried on a trade should take into account financing activities at the partner level, Arden LJ stated (at para. 72): [T]he distinction between partnership activities and the affairs of individual partners is clearly recognised both in the authorities and in the legislation.... ...

MEO — Serviços de Comunicações e Multimédia SA v. Autoridade Tributária e Aduaneira (2018), ECLI:EU:C:2018:942 (ECJ (5th Chamber))-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) fee for early termination of services contact was consideration for the service Subscribers to the services of a Portuguese telecommunications company (“MEO”) agreed to pay for a minimum subscription period, and when they discontinued service before the end of that guaranteed period they were required under the terms of their contracts to pay a lump sum equal to their monthly subscription fee multiplied by the number of remaining months in the guaranteed period. ...

Hancock & Anor v Revenue and Customs, [2019] UKSC 24-- summary under Absurdities Summary Under Tax Topics- Statutory Interpretation- Absurdities Luke principle that a stained interpretation can be adopted to implement clear Parliamentary intention Lady Arden referred with apparent approval to the principle in Luke v Inland Revenue Comrs [1963] AC 557, stating (at para. 24): This enables the court, when interpreting a statute, to adopt (my words) a strained interpretation in place of one which would be contrary to the clear intention of Parliament. ...