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Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The parenthetical expression refers to the method regularly followed by the taxpayer for financial statement purposes. ...

Thames Bandag & Tire Ltd. v. The Queen, 88 DTC 6417, [1988] 2 CTC 203 (FCTD)-- summary under Subsection 224(1) Summary Under Tax Topics- Income Tax Act- Section 224- Subsection 224(1) After a secured creditor ("Bandag") of a company ("Olympic") had made a demand, following the default of Olympic, on the debtors of Olympic to pay their debts to Bandag, the Crown successfully made a demand on Bandag pursuant to s. 52(10) of the Excise Tax Act. ...

Hughes & Co. Holdings Ltd., 94 DTC 6511, [1994] 2 CTC 170-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business at least six A practising lawyer who spent approximately 28 hours per year on telephone calls monitoring the business of the taxpayer in addition to making occasional visits to the taxpayer's office in consideration for annual remuneration from the taxpayer of $8,250 did not qualify as a "full-time employee". ...

Coopers & Lybrand Ltd. v. Bank of Montreal, [1993] GSTC 36 (Nfld. ...

Javalin Founderies & Machine Works Ltd. v. MNR, 67 DTC 392 (TAB)-- summary under Subsection 69(4) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(4) In finding that a transaction under which the individual non-resident shareholder of a Canadian corporation took possession of all its assets after the corporation ceased to carry on business transactions subject to s. 17(5), the Board noted (at p. 398) that "if the purpose of section 17... is to prevent companies from understating their income by distributing stock-in-trade to shareholders either as gifts or upon winding-up without ascribing any value thereto in terms of payment by the shareholder", whereas here the shareholder had taken possession of capital assets. ...

James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 "S.231(3) is only available to the Minister to obtain information relevant to the tax liability of some specific person or group of persons if the tax liability of such person or persons is the subject of a genuine and serious inquiry. ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC)-- summary under Active Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Active Business Interest income which the corporate taxpayer, which was in the business of selling and servicing equipment used in the mining industry, earned on term deposits was held to be active business income. ...

Saskatoon Drug & Stationery Co. Ltd., 78 DTC 6396, [1978] CTC 578 (FCTD)-- summary under Class 13 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 13 The taxpayer acquired a leasehold interest in a drug store. ...

Rowntree & Co. Ltd., [1948] 1 All ER 482 (CA)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer drew sight bills on an acceptance house which, after accepting the bills, discounted them in the market as agent for the taxpayer and remitted the proceeds to the taxpayer. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Noscitur a Sociis Summary Under Tax Topics- Statutory Interpretation- Noscitur a Sociis With respect to a submission that the more general word "management" in the phrase "management or administration fee" in s. 212(1)(a) should be coloured by the word "administration", Cullen J. stated (p. 5089): "Such an approach fails to give sufficient weight to the fact that the words 'management' and 'administration' are divided by the disjunctive 'or', which tends to suggest that the words were intended to bear separate meanings. ...