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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. ...

Canada, 97 DTC 5363, [1997] 2 S.C.R. 336, [1998] 1 CTC 213-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt unrecorded revenues In connection with finding that the taxpayer had generated revenues, which were not reflected in its financial statements, from holding leasing assets for five days, L'Heureux-Dubé J. stated (at para. 87): The law is well established that accounting documents or accounting entries serve only to reflect transactions and that it is the reality of the facts that determines the true nature and substance of transactions: Vander Nurseries Inc. v. ...

Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as payment The wholly-owned Canadian subsidiary of the taxpayer declared a dividend, with the resolution stipulating that the dividend was "to be payable by the Corporation by the issuance of a demand promissory note". ...

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 Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) consistent LIFO use generally is acceptable In commenting on the Anaconda case, Reed J. stated (p. 5298): "... ...

A & W TradeMarks Inc. v. The Queen, 2005 TCC 493 (Informal Procedure)-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) fees incurred in connection with parent’s issuing units, with proceeds used in the registrant’s business, were eligible The appellant, which became a wholly-owned subsidiary of a new income fund (the “Fund”), incurred $78,000 in fees directly to an investment dealer, law firms and a printing company in connection with the IPO of the Fund. The $83M proceeds of the IPO were used by the Fund to subscribe for debt and equity of the appellant which, in turn, used those proceeds to acquire trade marks from another A & W company for licensing back to that company. ...

., [2009] 1 S.C.R. 15-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no prior oral agreement The parties entered into an employment contract that included a restrictive covenant, providing that the defendant would not be employed in the business of insurance brokerage within the "Metropolitan City of Vancouver" for three years after leaving employment with the plaintiff. ...

The Queen, 2016 TCC 137-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt funds in leveraged donation scheme essentially advanced by lender directly to charity A Quistclose trust (as described by C. ...

The Queen, 2018 TCC 189 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt taxpayer had "physically" received govenment assistance funds with freedom to transfer Although all the conditions for the receipt of government assistance had not yet been (and never were) satisfied, Campbell J found that the taxpayer had “physically acquired” the funds in question through depositing a cheque to a trust account of its own formation and thereafter disbursed the funds out of the account to fund its project without any practical hindrance by the government foundation in question (which appeared to have waived the condition referred to above). ...

The Queen, 2019 TCC 135-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt advance on another party’s behalf established a loan The taxpayer (“Black”) controlled both Hollinger Inc. ...

The Queen, 2020 TCC 47, aff'd 2022 FCA 72-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development programming costs were not SR&ED The taxpayer (“National”), which provided consulting services to clients, claimed to have made SR&ED expenditures of $68,029 and generated investment tax credits of $23,810 in connection with developing a computer program that would automate aspects filing SR&ED claims with the CRA through a web-based, cross-platform and cross-browser framework to track claimable SR&ED projects. ...