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Keir & Cawder, Ltd. v. C.I.R. (1958), 38 TC 23 (C.S. (1st Div.))-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, whose main activity was carrying on the trade of quarrymasters, sought to extend its business to civil engineering contracting by retaining a firm of consulting engineers to provide the services and reputation of one of their engineers. ...

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Before finding that a clause in a lease giving the lessee the unilateral right to compel the lessor to sell helicopters to the lessee at their reasonable fair market value was an "option", Major J. stated his agreement with the following list of the three principal features of an option: exclusivity and irrevocability of the offer to sell within the time period specified in the option; specification of how the contract of sale may be created by the optionholder; and obligation of the parties to enter into a contract of sale if the option is exercised. ...

Osler, Hammond & Nanton Limited v. Minister of National Revenue, 63 DTC 1119, [1963] CTC 164, [1963] S.C.R. 432-- summary under Shares Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Coopers & Lybrand Ltd., 80 DTC 6281, [1980] CTC 367 (FCA)-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) payroll not paid by receiver as agent of debtor The payment by a privately-appointed receiver-manager of the unpaid wages of the employees of the debtor company (1) was the payment of "salary or wages" (as opposed to "gratuitous benefactions made in order to earn and preserve the good-will of the persons who had been employees of" the debtor company, as was contended by the receiver-manager) and (2) was made by the receiver-manager on its own decision, and not by the debtor company (notwithstanding that the debenture stated that the "receiver shall for all purposes be deemed to be the agent of the Company".) ...

Coopers & Lybrand Ltd., 80 DTC 6281, [1980] CTC 367 (FCA)-- summary under Salary or Wages Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary or Wages receiver's payment of unpaid wages was of "salary or wages" A privately-appointed receiver-manager, who paid the unpaid wages of the employees of the debtor company, argued that those amounts "were not wages but were gratuitous benefactions made in order to earn and preserve the good-will" of those persons. ...

Capital City Savings & Credit Union Ltd. v. 299474 Alberta Ltd., [1990] 3 WWR 763 (Alta. ...

Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose In 1952, the taxpayer purchased 52 acres of land outside Montreal in order to construct its own facilities for use in research, manufacturing and marketing. ...

Abercorris Slate & Slabe Co. (1887), 37 Ch. D. 260, [1886-90] All ER 509-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Chitty J. stated (at Ch.D. p. 264): In my opinion a debenture means a document which either creates a debt or acknowledges it, and any document which fulfills either of these conditions is a "debenture. ...

Addison & Leyen Ltd. v. Canada, 2006 DTC 6248, 2006 FCA 107-- summary under Perpetual Obligations Summary Under Tax Topics- Statutory Interpretation- Perpetual Obligations Sharlow J.A. stated (at p. 6260) that "it requires clear and explicit statutory language to deprive... a person of recourse to the minimal protection afforded by the right to seek judicial review of the exercise of the Minister's discretion" after expressing "considerable discomfort with the notion of a statutory obligation that may exist in perpetuity, subject only to the discretion of the Minister", which was the case with respect to assessments under s. 160 of the Act. ...

Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 Article 5 of the Canada-U.K. ...