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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 Paragraph 81(1)(c) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(c) 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 the rate setting and other activities in the Canada-U.K. ...

Hudson Bay Mining & Smelting Co. v. R., 99 DTC 5269, [1999] 3 CTC 76 (FCA)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer repurchased some of its outstanding debentures through brokers. ...

Lloyds & Scottish Finance Ltd. v. Cyril Lord Carpets Sales Ltd., [1992] B.C.L.C. 609 (HL)-- summary under Paragraph 20(1)(n) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(n) A "block discounting" master agreement was found to establish that the taxpayer was assigning by way of sale to the respondent the amounts receivable by it under hire purchase contracts, rather than making assignments by way of charge, notwithstanding that in practice the arrangement worked in essentially the same manner as if the respondent were advancing to the appellant 80% of the receivables less the agreed discount. ...

(formerly Fortin & Moreau Inc.), 98 DTC 6401 (FCTD), rev'd 99 DTC 5841 (FCA)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property The Quebec taxpayer leased various vehicles. ...

Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange for the right to salvage the wreckage), but the obligation only triggered when the respondent gave the appellant possession of the building to be demolished. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 212(1)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(a) The taxpayer, which was the portfolio manager of the Cundill Value Fund and the Cundill Security Fund (the "Funds"), contracted with a Bermuda company ("PCAB") for the investment counselling and transaction skills of F. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) dependency on name fund manager and 50% owner The taxpayer, which was the portfolio manager for the Cundill Value Fund and the Cundill Security Fund was dependent upon Mr. ...

Bairstow & Harrison, (1955), 36 TC 207, [1955] UKHL TC (HL)-- summary under Machinery and Equipment Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)-- summary under Paragraph 256(1)(b) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1)- Paragraph 256(1)(b) ignore voting agreements A corporation ("Burland") was owned by nine children of four fathers. ...

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) required transfer of value between subs not a benefit One company in a group of UK companies (the "Lender") made a loan to a subsidiary (the "Borrower"). ...