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Richter & Associates Inc v. The Queen, 2005 TCC 92-- summary under Illegality Summary Under Tax Topics- General Concepts- Illegality Act applied to what has occurred irrespective of legality In rejecting a submission that the trustee for a bankrupt company was not authorized by the Bankruptcy and Insolvency Act to engage in a "litigation support business" of providing assistance to most of the creditors in connection with their action sounding in negligence against company's former auditors, C&L for $800 million in damages, Archambault J stated (at paras. 33-4): [T]he Trustee, acting as agent for the Estate, was legally entitled to carry on the undertaking in question. … In any event, I would add that the Act is not to be applied to transactions that ought to have taken place, nor is it to be applied only to transactions that could be legally carried out. ...

The Queen, 2011 DTC 1282 [at at 1592], 2011 TCC 391-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development D'Arcy J. denied the taxpayer's claimed SR&ED credits arising from the development of various electrical systems for use in wheelchairs- a power optimizer to switch power between the front and back wheels of a wheelchair or scooter, an inhibitor to ensure that a wheelchair remain stationary while being charged, a virtual battery system to derive 36 volts of potential from two 12-volt batteries, and a multi-voltage output charger. ...

The Queen, 98 DTC 1877, [1998] 4 CTC 2618 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, which was engaged in researching and developing advanced data management and memory management software systems for large mainframe computers, and which had adopted the proxy method for calculating SR&ED expenditures, was able to include in s. 37(8)(a)(ii)(B)(I) the cost of a dedicated telephone line that was used to pass instructions and data from the taxpayer's employees in Ottawa (none of whom left Canada) to the staff of an independent company in Birmingham, Alabama whose mainframe computer the taxpayer was leasing for testing purposes. ...

The Queen, 2002 DTC 1749 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt funds to support cheques Miller T.C.J. noted that with respect to the situation where the taxpayer, which owed approximately $60 million in accrued interest, paid $60 million to the creditor at the same time that the creditor paid $60 million to the taxpayer as an addition to the advances owing by the taxpayer, that he had difficulty identifying any moment in time at which the taxpayer did not owe $60 million to the creditor. ...

., 2012 DTC 5118 [at at 7149], 2012 QCCS 2745 (Queb Sup Ct), aff'd supra-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The taxpayer paid a $136 million dividend to the non-resident corporate defendant when it was indebted to the defendant. ...

The Queen, 89 DTC 5333, [1989] 2 CTC 75 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by unauthorized agent not payment On November 24, 1980 the Department of Supply and Services issued a refund cheque to "Cumberland Properties Ltd. c/o John Church", which was the manner in which Cumberland's 1978 return had been completed. ...

., 2006 DTC 6124, 2005 NSSC 212 (NSSC)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission On two occasions, a Nova Scotia company ("Columbia") made cash distributions to its non-resident shareholder, purportedly as distributions of paid-up capital. ...

The Queen, 2015 DTC 1135 [at at 859], 2015 TCC 65 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development development of code analysis software entailed standard techniques Lamarre ACJ found that the taxpayer's development of code analysis software for websites was not experimental development. ...

Nevill & Co. Ltd. v. Federal Commissioner of Taxation (1937), 4 A.T.D. 187 (HC)-- 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. Expense- Contract or Option Cancellation In finding that instalments of a lump sum payment made by the taxpayer to a joint managing director in consideration of his cancelling his employment agreement with the company were expenditures of a capital nature, Dixon J. stated (at p.197) that the lump sum: "... was made for the purpose of organising the staff and as part of the necessary expenses of conducting the business. ...

The Queen, 95 DTC 194, [1994] 2 CTC 2416 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt book entry did not give rise to receipt In finding that the redesignation of a 'bonus payable' to 'due to shareholder' did not constitute the receipt of an amount giving rise to income in the taxpayer's hands, Bowman TCJ. stated (at p.196): "Nor can I accept that the mere bookkeeping entry of moving the amount of bonus owing to Mr. ...