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Lewis & Son Ltd. v. Kerman, [1970] 3 All ER 414 (CA)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.24(2)(g) of the Agricultural Holdings Act 1948 (U.K.) gave a landlord of an agricultural holding, such as the plaintiff, the right to determine the tenancy within three months of the death of the tenant with whom the contract of tenancy was made. ...

Morgan Stanley & Co International PLC, [2015] UKSC 12-- summary under Subsection 12(3) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(3) "accrue" describes the coming into being of a right or obligation Lord Reed stated (at para. 41): The word "accrue" is generally used to describe the coming into being of a right or an obligation (as, for example, in Aitken v South Hams District Council [1995] 1 AC 262), so that the person in question then has an accrued right, or is subject to an accrued liability, as the case may be. ...

Panther Oil & Grease Manufacturing Co. of Canada Ltd., 61 DTC 1222, [1961] CTC 363 (Ex Ct)-- summary under Subsection 400(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 400- Subsection 400(2) The taxpayer, whose factory in Ontario filled orders for roofing materials and lubricants generated by its sales force in various provinces, including Quebec, was found to have a "branch" in Quebec (notwithstanding that its large sales force there used their own homes) because "it had a component portion of its sales organization there" (p. 1230), and also had an "agency" in Quebec because its Quebec division manager and district managers "were its instrumentalities for the conduct of its sales in Quebec" (p. 1230). ...

Cancer Relief & Research Institute, [1939] 4 DLR 191 (Man. K.B.)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation corporation has separate legal personality In finding that an institute which section 2 of the Cancer Relief Act, 1930 (Manitoba) purported to make a "body corporate" was not, in fact, a corporation because there were no natural persons to compose or to constitute the corporation, Dysart J. stated (pp. 193-194): "What is a corporation? ...

Queen & Metcalfe Carpark Ltd. v. MNR, 74 DTC 6007, [1973] CTC 810 (FCTD), aff'd [1976] CTC xvi (FCA)-- summary under Paragraph 20(1)(dd) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(dd) engaged in a business/zoning, traffic flows and markets would be included A company in the business of acquiring various properties and leasing them out for rental use was held to be earning business income rather than property income (notwithstanding that its "rental income was income from the property itself rather than... payment in substantial measure for services") in light inter alia of its corporate objects. ...

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 152(1.12) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.12) The Minister made an assessment under s. 152(1.11) on the basis that the GAAR applied to reduce the paid-up capital of shares of a Canadian holding company ("Holdings") from $167 million to $475,000, and about ten days later assessed on the basis that previous purported distributions of about $104 million of paid-up capital ("PUC") by Holdings were subject to Part XIII tax. ...

T & S First Choice Renovations Limited v. Canada Revenue Agency, 2012 DTC 5152 [at at 7377], 2012 FC 1146-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) The taxpayer appealed the Minister's decision to deny relief of interest on corporate tax, payroll deductions, and GST accounts. ...

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 supplied asphalt was merely an accession to customers' real property The taxpayer, which paved driveways, parking lots and small roadways, also operated an asphalt-producing plant. 75% of the output was utilized in that paving business, and the balance was sold to third parties. ...

Thomas Nelson & Sons, Ltd. (1938), 22 TC 176 (C.S. (1st Div'n))-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The taxpayer lent money to its Indian subsidiary under an agreement which provided that interest was to be paid at 3% per annum (a "remarkably low rate for an unsecured loan") and that on repayment of the principal (which would occur in 10 years time, or earlier on the occurrence of certain specified events or on the election of the subsidiary to repay) a premium would be paid whose amount was based on 2% per annum for the first two years during the term of the loan, and 2 1/2% per annum thereafter. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence The taxpayer, which was a resident of the U.K. and carried on an international shipping business both directly and through subsidiaries, provided various services through its Canadian branch office in respect of both its own ships and those of subsidiaries, including the provision of stevedoring services, the finding and booking of cargo for the ships and attending and participating in rate setting and other activities of the Canada-U.K. ...