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Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) Kerr, J. indicated, obiter, that s. 18(1)(e) would have applied to unpaid bonuses which the taxpayer sought to deduct: "When the decision to pay bonuses was taken in the fall of 1968 the amount that would be paid was uncertain, although a range of $25,000 to $30,000 was decided, and payment was contingent on necessary funds being available". ...

Customs & Excise Commissioners v. Redrow Group plc, [1999] BTC 5062 (HL)-- summary under Recipient Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Recipient The Appellant, which was in the business of building new homes, offered to prospective buyers of its homes the services of real estate agents who would act in the sale of their existing homes, and had undertook to pay the agents' fees provided that the purchase of the new house from the Appellant went through. ...

B & B Royalties, Ltd. v. MNR, [1940-1941] CTC 65 (Ex Ct)-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income The taxpayer was found to have alienated its interest in a portion of the production of oil and gas from leased lands, or the proceeds of such production, to a trustee for various unit holders. ...

Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) purchases of stationery could be deducted when acquired The taxpayer was entitled to deduct in the year of acquisition the costs of supplies of stationery and special forms that it had on hand at the end of the year notwithstanding that it included those costs in the inventory shown on its balance sheet. ...

Smidth & Co. v. F. Greenwood (1921), 8 TC 200 (CA), aff'd 206 (HL)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) mere installation in jurisdiction The taxpayer, which manufactured cement-making equipment in Denmark, delivered the machinery F.O.B. at Copenhagen, and concluded the sales contracts in Denmark was found not be exercising a trade in the United Kingdom notwithstanding the maintaining of a sales office in London where a full-time employee inspected the site of proposed installations, forwarded samples to Denmark for testing, and superintended installations of the machinery. ...

Young, Austen & Young Ltd., [1987] BTC 530 (HCJ), rev'd [1989] BTC 77 (C.A.)-- summary under Interpretation/Definition Provisions Summary Under Tax Topics- Statutory Interpretation- Interpretation/Definition Provisions "includes means a wide range of things "[T]he word 'include' may be used in such a definition to enlarge the natural meaning of the word defined, or to clarify it, or to introduce examples of its meaning, or to introduce restrictions on that meaning, or for two or more of those purposes. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- Section 103- Subsection 103(1) "salary" to partner is a profits distribution In discussing the nature of a partnership, Lord Oliver stated (p. 900): "A partner working in the business or undertaking of the partnership is in a very different position from an employee... ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Paragraph 96(1)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(a) Lord Oliver rejected a finding of the Court of Appeal that a firm of accountants could be regarded as a "notionally distinct entity" in order to assess the purpose of expenditures incurred by it in reimbursing the relocation expenses of its partners. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Paragraph 96(1)(f) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1)- Paragraph 96(1)(f) "salary" to partner is part of profits division Lord Oliver stated (p. 589) that "if, with the agreement of his partners, [a partner] pays himself a 'salary', this merely means that he receives an additional part of the profits before they fall to be divided between the partners in the appropriate proportions. ...

Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL)-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 partner salary is a draw In discussing the nature of a partnership, Lord Oliver stated (p. 900): A partner working in the business or undertaking of the partnership is in a very different position from an employee... ...