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Thomas Nelson & Sons, Ltd. (1938), 22 TC 176 (C.S. (1st Div'n))-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) The taxpayer lent money to its Indian subsidiary under an agreement which provided that interest was to be paid at 3% per annum (a "remarkably low rate for an unsecured loan") and that on repayment of the principal (which would occur in 10 years time, or earlier on the occurrence of certain specified events or on the election of the subsidiary to repay) a premium would be paid whose amount was based on 2% per annum for the first two years during the term of the loan, and 2 1/2% per annum thereafter. ...

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 Evidence Summary Under Tax Topics- General Concepts- Evidence The taxpayer, which was a resident of the U.K. and carried on an international shipping business both directly and through subsidiaries, provided various services through its Canadian branch office in respect of both its own ships and those of subsidiaries, including the provision of stevedoring services, the finding and booking of cargo for the ships and attending and participating in rate setting and other activities of the Canada-U.K. ...

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 Paragraph 81(1)(c) Summary Under Tax Topics- Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(c) The taxpayer, which was a resident of the U.K. and carried on an international shipping business both directly and through subsidiaries, provided various services through its Canadian branch office in respect of both its own ships and those of subsidiaries, including the provision of stevedoring services, the finding and booking of cargo for the ships and attending and participating in the rate setting and other activities in the Canada-U.K. ...

Hudson Bay Mining & Smelting Co. v. R., 99 DTC 5269, [1999] 3 CTC 76 (FCA)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer repurchased some of its outstanding debentures through brokers. ...

Lloyds & Scottish Finance Ltd. v. Cyril Lord Carpets Sales Ltd., [1992] B.C.L.C. 609 (HL)-- summary under Paragraph 20(1)(n) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(n) A "block discounting" master agreement was found to establish that the taxpayer was assigning by way of sale to the respondent the amounts receivable by it under hire purchase contracts, rather than making assignments by way of charge, notwithstanding that in practice the arrangement worked in essentially the same manner as if the respondent were advancing to the appellant 80% of the receivables less the agreed discount. ...

(formerly Fortin & Moreau Inc.), 98 DTC 6401 (FCTD), rev'd 99 DTC 5841 (FCA)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property The Quebec taxpayer leased various vehicles. ...

Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange for the right to salvage the wreckage), but the obligation only triggered when the respondent gave the appellant possession of the building to be demolished. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 212(1)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(a) The taxpayer, which was the portfolio manager of the Cundill Value Fund and the Cundill Security Fund (the "Funds"), contracted with a Bermuda company ("PCAB") for the investment counselling and transaction skills of F. ...

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) dependency on name fund manager and 50% owner The taxpayer, which was the portfolio manager for the Cundill Value Fund and the Cundill Security Fund was dependent upon Mr. ...

Bairstow & Harrison, (1955), 36 TC 207, [1955] UKHL TC (HL)-- summary under Machinery and Equipment Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...