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The Queen, 78 DTC 6339, [1978] CTC 485 (FCA)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Legal fees incurred in connection with an abortive attempt to take over a company were made on capital account. ...

"The expenses incurred in connection with the partially completed signs were laid out to bring in income in the next or some other taxation year, not in the year in which they were claimed. ...

Archambault T.C.J. found that the expenses of that partnership incurred in connection with the unit rented to the taxpayer's wife (and a pro rata portion of interest on money borrowed to fund his partnership interest) were not incurred for an income-producing purpose. ...

., 77 DTC 5091, [1977] CTC 151 (FCTD)-- summary under Old Summary Under Tax Topics- Income Tax Act- Section 245- Old A fee of $61,317 which a subsidiary paid to its parent for services that the parent (primarily in the person of its shareholder and officer) performed in connection with taking the parent public so as to obtain funds to expand the subsidiary's business, was found to be reasonable, notwithstanding that (1) the amount of the fee equalled what otherwise would have been the net loss of the parent for the fiscal year in question, (2) the principal shareholder of the parent received relatively small amounts for the services he performed as officer for the subsidiary and (3) the absence of a written agreement. ...

The Queen, 2013 TCC 352 (Informal Procedure)-- summary under Section 135 Summary Under Tax Topics- Excise Tax Act- Section 135 The appellant ("CCAN") was a not-for-profit organization which, in connection with the promotion of environmental responsibility, would produce and distribute tailgate magnetic stickers, posters, signs, etc., to discourage idle engine operation. ...

In addition to doubting on the evidence that the partnership had made such a loan, Boyle J. noted that the loan had no apparent connection to the partnership's business. ...

The Queen, 2008 TCC 62-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) In finding that legal and other fees incurred by the taxpayer in connection with his prosecution for crimes committed while he was employed by a different corporation than the corporation which reimbursed him for those fees were, when so reimbursed, a taxable benefit to him, Tardif, J. noted that the test was whether the reimbursements were intended to remedy a prejudice caused by his employment and, on that basis, the reimbursements were a taxable benefit. ...

Accordingly, the taxpayer was able to deduct his share of certain losses of the partnership notwithstanding that, in light of their awareness of the misrepresentation, the general partners (through a trustee) refused to cash the cheque or realize upon the promissory note provided by the taxpayer in connection with his subscription. ...

Although the taxpayer maintained that, given that he spent only 57 days in Canada in the year in question in connection with his duties as director, only 57/366 of this sum was taxable in Canada, Rouleau J. upheld the Minister's reassessment that 1/2 of the amount was taxable under s. 115(2)(e) in the absence of any convincing evidence that the taxpayer had devoted a significant amount of time outside Canada to the Canadian company. ...

The trial judge found that the resulting taxable benefit should be valued at the costs incurred by the school in connection with the taxpayers' children minus the tuition paid. ...