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S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business The sole shareholder ("Ross") of the taxpayer served as the CFO of a Canadian company ("Clearly Canadian") and also performed services on behalf of the taxpayer for Clearly Canadian. ...

London & Quadrant Housing Trust, [1999] 3 WLR 150 (HL)-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex licensee granted tenancy A housing trust that had been granted a licence by the local authority to use a number of properties for redevelopment as temporary accommodation for homeless persons and which signed an agreement with the plaintiff for occupation of a self-contained flat in one of the properties on a temporary basis on a weekly licence was found to have thereby created a tenancy in favour of the plaintiff because the agreement with the plaintiff had all the characteristics of a tenancy, including the grant of exclusive possession. ...

Pizzolati & Chittaro Manufacturing Co. Ltd. v. May et al., [1971] 3 OR 768 (Ont HCJ)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract One defendant sold his business to the other. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence parol evidence rule applied to Minister Campbell J. found that the parol evidence rule prevented the Minister from bringing extrinsic evidence that would have shown that the taxpayer was disingenuous in the way it characterized one of its business contracts for tax purposes. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income The taxpayer's business was to facilitate B.C. municipalities in obtaining vehicles and equipment. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) deduction of head office expenses The Canadian branch office of the taxpayer, which was a U.K. ...

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085, [1970] CTC 99 (FCTD)-- summary under Paragraph 110.1(1)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.1- Subsection 110.1(1)- Paragraph 110.1(1)(a) donations deductible as business expenses rather than as gifts Gifts which the taxpayer made to Jewish organizations in the Montreal area in amounts over $100 were accepted to have been made for the purpose of increasing its sales and, therefore were deductible in computing its income. ...

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085, [1970] CTC 99 (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 donations deductible as business expenses rather than as gifts Gifts which the taxpayer made to Jewish organizations in the Montreal area in amounts over $100 were accepted to have been made for the purpose of increasing its sales and, therefore were deductible in computing its income. ...

Cunard & Company Limited v. Canada (Attorney General), 2012 DTC 5122 [at at 7192], 2012 FC 683-- summary under Subsection 85(7.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(7.1) not unreasonable to not permit late-filing by dissolved corporation Scott J. found that the Barnabe Estate principle, which allowed elections to be made by the estate of a deceased person, did not apply to a late-filed election by a corporation that had been wound up. ...

Baine, Johnstone & Co. Ltd., 77 DTC 5394, [1977] CTC 556 (FCTD)-- summary under Goodwill, Trademarks and Customer Lists Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...