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(k.1) In finding that the recurring costs of racks and boxes incurred by an exploration company in order to store core samples were capital expenditures, Fournier J stated (at para. 295, TaxInterpretations translation): The core boxes and racks allowed for the permanent preservation of a duplicate of each sample taken during exploration …. ...

In finding that these distributions did not entail the taxpayer giving consideration to the trust for s. 160 purposes, Gagnon J found that: “the trustee's distributions had no impact on the rights of a beneficiary of the Trust who had or had not received a distribution” (para. 65, TaxInterpetations translation); and although the taxpayer “had a right under the Trust to be considered by the trustee for any distribution on the same basis as the other beneficiaries … there is no reason to believe that anyone would have paid even a very small amount for [this right]” and “[i]n fact, it is highly unlikely that such a right could be transferred to a third party” (para. 67). ...

ARQ, 2025 QCCQ 1330-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) a CBCA corporation can be assessed within 2 years of its dissolution – or thereafter, if revived by the ARQ or CRA The ARQ assessed the taxpayer within two years of the taxpayer’s dissolution pursuant to s. 210(3) of the CBCA. ...

In concurring in a reversal of a finding of the full Federal Court that the "dominant purpose" of the taxpayer for purposes of Part IV of the Income Tax Assessment Act of 1936 was to obtain the maximum return on money invested after the payment of all applicable costs including tax, and not to obtain a tax benefit, McHugh J. stated: "... ...

. … I am not myself prepared to say that what amongst business men is equivalent to a receipt of a sum of money is not a receipt within the meaning of the Statute…. ...

Expense- Contract or Option Cancellation payment for surrender of key lease was capital In finding that lump sums paid by a colliery company in order to secure a reduction in the scope of (in one case) or the cancellation (in the other case) of two mining leases (and thereby release its liability to restore the surface) were on capital account, Lawrence L.J. first noted (at p. 787) that the company's trade did not consist of acquiring mining leases and selling those mining leases but, rather, of the winning and selling of coal, and then stated (at p. 788): "... it cannot, in my opinion, reasonably be said that the consideration paid for and the acceptance of the surrender was a sum wholly and exclusively expended for the purpose of winning and selling the coal in which the Company traded. ...

MacInnes & Co. and at the same time the effective elimination of that concern and its owner as a competitor. ...

. … The following provision is set out in the Taxation Regulations: 488R1… (e) an amount…that is exempt from income tax in Québec or in Canada by virtue of a provision of a tax agreement entered into with a country other than Canada; This provision is directed at avoiding double taxation and for that purpose only a tax convention concluded by Canada with another country applies to Quebec if its provisions exempt otherwise-taxable income from tax in Canada. ...

See summary under General Concepts – Rectification. ...

In rejecting the contention of Revenue that the cost of the securities to the taxpayer should be based on their fair market value at the time of acquisition rather than on the amount of the debenture and the par value at which the shares were issued, Lord Wright stated (pp. 289-290)): "... ...