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Young, Austen & Young Ltd., [1989] BTC 77 (C.A.)-- summary under Subsection 86(1) Summary Under Tax Topics- Income Tax Act- Section 86- Subsection 86(1) In finding that an issuance of shares by a company to its existing beneficial shareholder, followed by the application of the subscription proceeds to pay off intercompany indebtedness, was a "reorganization... of a company's share capital" on ordinary principles, Balcombe L.J. stated: "an increase of share capital can be a reorganization of that capital... provided that the new shares are acquired by existing shareholders because they are existing shareholders and in proportion to their existing beneficial holdings. ...

Weiss, Biheller & Brooks, Ltd. v. Farmer (1922), 8 TC 381 (CA)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) agent distributor The taxpayer, which was an English company carrying on business as an importer and merchant, and which was the exclusive distributor of gas mantles manufactured by a Dutch company, was found to have been properly assessed as agent for the Dutch company in respect of profits derived by the Dutch company in carrying on a trade within the United Kingdom as vendor of the gas mantles, notwithstanding that there was no privity of contract between the English customers and the Dutch company, and that property in the mantles may have passed to the taxpayer. ...

& E. Cmners. v. West Yorkshire Hospital (Contract Services) Ltd., [1988] BTC 5095 (Q.B.D.)-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning "First, while (the context apart) one would expect payment to be construed in its ordinary sense, it is a well recognized legal concept. ...

& J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing The taxpayer was unsuccessful in deferring the recognition of income under contracts relating to the installation of manufacturing equipment to the year of completion of the contracts, rather than the time of receipt of amounts under the contracts, given that the amounts received were not subject to any restrictions as to disposition, use for enjoyment. ...

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. ...

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. ...

Kibby & Anor., [1993] BTC 291 (D)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Vice-Chancellor Nicholls affirmed the finding of the Commissioner that the purchase as a going concern by the taxpayers of an existing fish and chip shop business in a village five miles away, followed by the continued conduct of that business from the same premises but with substantial variations in the mode of conduct thereof should be characterized as an expansion by the taxpayers of their own fish and chip business into the new premises, rather than as a continuation of the trade carried on by the former owner at the new premises. ...

Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)-- summary under Subparagraph 212(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(b)- Subparagraph 212(1)(b)(ii) The Ontario Development Corporation was a Crown agency within the meaning of s. 1 of the Crown Agency Act (Ontario) given that: the Crown owned all its shares; the Crown appointed all its directors, the permanent staff of the corporation were members of the public service; and the corporation was subject to the control of the Crown in the most fundamental aspects of its financial structure and operation. ...

Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense gratuitous bonus In respect of its 1969 and 1970 taxation years the taxpayer deducted management bonuses whose quantum was not ascertained until after the end of the taxation year and which, due in part to a reduction in the taxpayer's profitability, were not paid. ...