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Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545-- summary under Subsection 92(2) Summary Under Tax Topics- Other Legislation/Constitution- Constitution Act, 1867- Subsection 92(2) provincial tax styled as a direct "income tax" was in substance an ultra vires indirct tax on oil exports In order to divert to itself the increase in the price of oil that occurred after 1973, the Legislature of Saskatchewan enacted a "mineral income tax" approximately equal to 100% of the difference between the price received at the well-head and the price formerly received by the producers. ...

Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax Dickson, J. made a finding (at p. 477) in which the majority concurred (at p. 458) that a "mineral income tax" which effectively taxed 100% of the difference between the price received by oil producers at the well-head and the price they formerly received before the increase in oil prices following the 1973 energy crisis, was not an income tax: "The tax is not levied upon net income. ...

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 Paragraph 20(1)(l) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(l) The taxpayer for tax and financial statements purposes claimed reserves for doubtful accounts which were significantly in excess of its actual bad debt write-offs for the following year in light of its policy of continuing to make sales to high risk and past due accounts rather than writing off such accounts. ...

Les Placements A & N Robitaille Inc. v. MNR, 96 DTC 1062, [1996] 1 CTC 2141 (TCC)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital Archambault TCJ. found that a business of manufacturing or reconditioning and selling boats or other nautical products had goodwill that was not purely personal to the shareholder-manager of the corporate owner of the business given that, on the evidence, a sale of such business would have occurred for a purchase price in excess of the value of the tangible assets. ...

Laurent Goulet & Fils Inc. v. MNR, 92 DTC 1611 (TCC)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property At the time the taxpayer contacted the lessor ("Hewitt") of equipment to it that it wished to exercise the purchase option, Hewitt suggested another institution ("Lafleur") as a source of financing the purchase. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus At the time of reassessing the taxpayer, Revenue Canada indicated that it regarded the taxpayer's interest in a property as having been acquired in exchange for services to be provided by the taxpayer. ...

Vancouver A & W Drive-Ins Ltd. v. United Food Services Ltd. (1981), 13 BLR 89 (BCSC)-- summary under Paragraph 146(2)(a) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(a) It was stated in response to an argument that the Act operates to deprive an annuitant of his right to terminate an R.R.S.P. trust: "It is one thing to say you cannot have a plan which provides for payment of benefits before maturity- which is what s. 146(2)(a)(i)(A) says. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...