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Manley, 85 DTC 5150, [1985] 1 CTC 186 (FCA)-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Mahoney, J. stated that Atkins is authority "for the proposition that an amount paid in settlement of a claim for damages for wrongful dismissal is not salary", but " Atkins is not, and does not purport to be, authority for the proposition that damages, or an amount paid to settle a claim for damages, cannot be income for tax purposes. ...

Since, at the time of signing the royalty agreement the licensee's estimated net sales for the following three years were only $1,500,000, only $75,000 (= 5% x $1,500,000) was includible in the taxpayer's income under s. 12(1)(g). ...

MNR, 95 DTC 5416 (FCTD)-- summary under Paragraph 22(1)(b) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Privacy Act- Paragraph 22(1)(b) Explanations provided by the Minister such as "disclosure of this information would prejudice the integrity of the investigation and therefore be injurious to the enforcement of the Income Tax Act " were insufficient to establish that disclosure of information should not be made. ...

Tekmark Global Solutions LLC (2010), 38 SOT 7 (Mumbai ITAT)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 no services provided through seconded employees As a U.S. resident (" Tekmark") had provided personnel only to work under the control and supervision of a resident of India ("Lucent") and did not render any technical services to Lucent through these personnel, the deputation of such personnel did not create a services PE. ...

Poirier, 92 DTC 6335, [1992] 2 CTC 9 (FCA)-- summary under Subsection 31(1) Summary Under Tax Topics- Income Tax Act- Section 31- Subsection 31(1) In finding that an operation of raising Charolais cattle was not the taxpayer's chief source of income, MacGuigan J.A. stated: "... it is patent to us that farming was in a subordinate position to the respondent's employment occupation. ...

Minister of National Revenue, 97 DTC 5126, [1997] 2 CTC 30 (FCA)-- summary under Purpose/Intention Summary Under Tax Topics- General Concepts- Purpose/Intention Robertson J.A. stated (at p. 5135) after discussing jurisprudence on paragraph 20(1)(c): "... ...

The Queen, 2016 TCC 260 (Informal Procedure)-- summary under Registrant Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Registrant registrant based on wind-up activities Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” – whose definition includes a “person who is required to be registered”- given that it still held equipment which it was seeking to sell (some of which it sold eight months’ later). ...

General Provisions provision dealing with only certain situations was the more specific After stating (at para. 29) that “arguably there is a conflict between subsection 141.01(2) of the Act and subsection 141.1(3) of the Act," Webb JA stated (at para. 30): Because subsection 141.1(3) of the Act is the more specific provision that only applies in certain situations, it will override subsection 141.01(2) …. ...

The Queen, 2010 DTC 1206 [at at 3541], 2010 TCC 310-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) sloppy bookkeeping ≠ gross negligence In finding that the portion of penalties assessed against the taxpayer that were based on related company expenses should be reversed, Woods, J. stated (at para. 42) that: It is quite possible that these errors were a matter of sloppy bookkeeping. ...

., docket A-663-99 (FCA)-- summary under Subsection 225(1) Summary Under Tax Topics- Excise Tax Act- Section 225- Subsection 225(1) In finding that the respondent was responsible for remitting any GST it had collected with respect to its exempt supply of full-time vocational training, Sharlow J.A. stated: "... a taxpayer who has in fact collected GST, whether for services that are taxable or for services that are later determined to be exempt supplies, must remit those amounts as liable to be assessed if they are not remitted. ...