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Brodie & Anor, [1998] BTC 141 (Ch. D)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law Before rejecting a submission by the Inspector of Taxes that the position of the taxpayers, as members of a Scottish partnership, should be the same as if they were members of an English partnership, Park J. stated (at p. 154) that: "... ...

The Queen, 2015 DTC 1013 [at at 64], 2014 TCC 334-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payments not received where children "recipients" had no control over funds Purported distributions out of a purported EPSP to children employees of the taxpayer were to a bank account controlled by the father, so that the participants "never had control of these funds" (para. 40), and so that the "real transactions" were "the payment of amounts by the corporation to the father" (para. 42). ...

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Accounting Principles Summary Under Tax Topics- General Concepts- Accounting Principles Before going on to affirm the deductibility under s. 20(1)(l) of an allowance for doubtful accounts which the taxpayer had taken for tax and financial statement purposes, Reed J. stated (p. 5297): "... in determining a reserve for doubtful debts, the principal factors that are used for the preparation line.gifl statements, as governed by the generally accepted accounting principles approved by the Canadian Institute of Chartered Accountants, are applicable, unless: (1) the Income Tax Act expressly requires otherwise or (2) the Income Tax Act implicitly requires otherwise. ...

C.R. 272 (Ex Ct)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note issued evidencing payment obligation Dividends on preference shares of a corporation, including those held by the taxpayer, were substantially in arrears. ...

., File No. 500-17-125795-230 (Quebec Superior Court)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission annulment ordered of two donations The plaintiff (the Foundation) received two donations, each of $70,000, from the defendant (Millenium) in July 2016 and July 2017. ...

Canada (Attorney General), 2008 DTC 6657, 2008 FC 1037-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt embedded royalty reduction was not an amount received The Alberta government granted a reduction in the royalties the taxpayer otherwise would have been required to pay to Alberta on condition that the taxpayer invest in an expansion of the Syncrude project. ...

(Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission requested rectification order to fix bump did not match parties' specific plan at closing The Bump Mistake A predecessor in interest of the applicant ("Viking") entered a multi-step acquisition and restructuring transaction to acquire an arm's length corporation ("Krang"). ... Dario J dismissed the taxpayer's application, stating (at paras. 77, 81 and 82): [T]his is not a case of the parties "wrote it down wrong", but rather the parties got it wrong. … To the extent we are talking only about the increased bump room due to the Krang Debt, the evidence does not establish that the inability to benefit from this tax treatment would have terminated the acquisition, or that the common intent of the parties that drove them to the formation of the transaction was frustrated. … The intent to complete a transaction in the most tax efficient manner possible is not sufficiently specific. ...

The Commissioner of Income Tax & Anr., Civil Appeal Nos. 8733-8734 of 2018, 2 March 202, Supreme Court of India-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 consideration for software paid by Indian resellers was not royalties for Canadian (and other) Treaty purposes At issue were numerous joined appeals involving the application of withholding tax by the Commissioner of consideration paid by residents of India to non-residents under four broad categories of licensing and sale transactions described below and involving the application of 18 income tax conventions (listed at para. 40, and described at para. 41 as being relevantly “substantially similar”) including that with Canada: Category 1: Computer software purchased directly by an end-user, resident in India, from a foreign, non-resident supplier or manufacturer (for example, a non-exclusive licence to use Samsung software on the end-user’s Samsung mobile device, with a prohibition against making the software available to any other person, or copying it other than for backup purposes). ... Nariman J noted (at paras. 47, 52): In all these cases … no vestige of copyright is at all transferred, either to the distributor or to the end-user. … What is “licensed” by the foreign, non-resident supplier to the distributor and resold to the resident end-user, or directly supplied to the resident end-user, is in fact the sale of a physical object which contains an embedded computer programme, and is therefore, a sale of goods. ... This would be the case regardless of whether the copies being distributed are delivered on tangible media or are distributed electronically (without the distributor having the right to reproduce the software) …. ...

.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no payment on capitalization of interest The taxpayer, who held bonds on which the payment of interest had been suspended, exchanged his matured interest coupons on the bond for interest-bearing 20-year funding bonds of the debtor. ...

., 98 DTC 1836, [1998] 3 CTC 2096 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt creditor may apply payment as it determines if debtor does not 'The taxpayer received two cash payments of $10,000 and $25,000 on an interest-bearing promissory note for $525,000 owing by an arm's length debtor. ...