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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. ...

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. ...

Gadsden & Co. Ltd. v. C.I.R. (N.Z.) (1964), 14 A.T.D. 18 (N.Z.S.C.)-- summary under Contract or Option Cancellation Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Walker & Co. v. C.I.R. (1920), 12 TC 297 (KBD)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) A partnership borrowed £4,000 from the executors of an estate pursuant to a loan agreement which provided that the consideration for the loan consisted of "the sum of £200 per annum payable half-yearly... and further a three-twentieth part of the profits in excess of £1,000 per annum up to but not in respect of any profits exceeding £3,000 per annum. ...

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business taxable share interest on loan held by affiliate One company in a group of UK companies (the "Lender") made a loan to a subsidiary (the "Borrower"). ...

Grainger & Son v. Gough (1896), 3 TC 462 (HL)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) soliciting orders was merely ancillary In finding that a French wine producer was not exercising a trade in the U.K. by virtue of English agents receiving orders for the wine and transmitting them to France for approval, Lord Hurschell stated (p. 467): "If all that a merchant does in any particular country is to solicit orders, I do not think that he can reasonably be said to exercise or carry on his trade in that country. ...