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Al Saunders Contracting & Consulting Inc., 2020 FCA 89-- summary under Hansard, explanatory notes, etc. ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing backdating of effective time of sales tax refund A federal sales tax refund was not receivable by the taxpayer until the Minister had given some public and irrevocable indication thereof. ...

Coopers & Lybrand Ltd., 80 DTC 6281, [1980] CTC 367 (FCA)-- summary under Subsection 227(9) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9) The payment by a receiver-manager of the net amount of the unpaid wages of the employees of the debtor company, without any deduction or remittance on account of taxes, was characterized as a default under S.227(8) (resulting in a 10% penalty) rather than S.227(9) (under which, prior to its replacement by the present ss.227(9) and (9.4) there in effect was a 110% penalty). ...

Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)-- summary under Subsection 5903(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903- Subsection 5903(3) A U.S. resident corporation ("Trans World U.S. ...

Bank & Trust Co. v. Eelman (1936), 183 Atlantic Reporter 677, 116 N.J. 279 (Sup Ct of NJ)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract In satisfaction of a prior judgment against the defendant, the plaintiff sought an order for garnishment of the monthly pension of the defendant, who was a retired police officer. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) manufacturing trade exercised in UK notwithstanding place of distributorship contracts tThe taxpayer ("Brentford"), which was a U.K. subsidiary of a U.S. corporation ("Akron") manufactured tires for sale, as agent for Akron, to distributors of Akron located in various countries including Sweden. ...

Rowe & Maw v. Customs and Excise Commissioners, [1975] 2 All E.R. 444 (Q.B.D.)-- summary under Section 178 Summary Under Tax Topics- Excise Tax Act- Section 178 In finding that charges of a firm of solicitors for reimbursement of their railway and air fares constituted, on general principles, part of the consideration for the services provided by them to their clients, Bridge J. stated (p. 448): "On the one hand a solicitor (like any other agent) may purchase goods or services for its client, as for instance when paying stamp duty, court fees, or buying, say, a travel ticket to enable the client to travel. ...

Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA)-- summary under Canadian Investment Income Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Canadian Investment Income funds employed and risked in the business were used in the business Interest earned, on the investment of funds received by an insurance broker, during the period before those funds had to be paid to the insurers, was held not to be Canadian investment income under the pre-1979 version of the definition. ...

Roman Miniotas (Romeo’s Plumbing & Heating) v. The Queen, 2011 DTC 1078 [at at 420], 2011 TCC 43-- summary under Subsection 167(5) Summary Under Tax Topics- Income Tax Act- Section 167- Subsection 167(5) The taxpayer's accountant sent letters on 3 and 24 October 2007, appealing an assessment. ...