Search - connection

., 89 DTC 5404, [1989] 2 CTC 246 (FCA)-- summary under Separate Existence Summary Under Tax Topics- General Concepts- Separate Existence The taxpayer ("MerBan") in connection with a leveraged share acquisition arranged for borrowings to be made to two special purpose subsidiaries in order to limit its liability and to facilitate the use of an income debenture. ...

MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing The taxpayer, which followed the "completed contract" method of recognizing income on long-term contracts for the excavation of sewers and water systems for accounting purposes, was permitted to deduct all the costs incurred by it in connection with those contracts only in the years those costs were made or incurred. ...

Flanigan held that the accounting, legal and investment advisory fees incurred in connection with this reorganization all were deductible under s. 11(1)(cb)(i) and noted that it was not necessary for the issuance of the shares to have resulted in the raising of fresh capital. ...

The Queen, 94 DTC 1964, [1994] 2 CTC 2439 (TCC)-- summary under Section 68 Summary Under Tax Topics- Income Tax Act- Section 68 All the proceeds received by the taxpayer in connection with the sale of his land to TransCanada Pipelines Limited ("TCP") were to be characterized in that manner notwithstanding that prior to reaching an agreement for the sale, the taxpayer had sought TCP's agreement to instead pay him business interruption compensation in respect of TCP's plan to run gas pipelines under the surface of his property (rather than purchasing his land). ...

Whaling, Re, 99 DTC 5478, [1999] 4 CTC 221 (Ont CA)-- summary under Paragraph 146(2)(c.3) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(c.3) In connection with a loan to the taxpayer by the CIBC, which was the depositary for two RRSPs that he opened up with the CIBC, it was agreed that if he should fail to meet the repayment term for loans the bank made to him he would, at the bank's request, collapse the RRSPs in order to repay the loans, or if the RRSPs could not be collapsed, the funds in the RRSPs would be applied against the loans at maturity. ...

He used a room in his apartment for preparing weekly invoices (which he sent to his placement agency), updating his resumé, typing letters to prospective employers, and making calculations and preparing sketches in connection with the current engagement. ...

Profit- Real Estate The taxpayer was entitled to a fee for services rendered to the owner of a property in connection with the finding of a purchaser of a part interest in the property. ...

Accordingly, the $1.25 million was not incurred in connection with or incidental to or arising from a borrowing. ...

Salomon and Company Limited, [1897] AC 22 that a corporation is regarded in law as a legal entity with the personality of its own and it is quite distinct from its shareholders" (p. 1592), Christie ACJ found (at p. 1596) "that a person who acquires a share in a corporation does not thereby acquire an interest in land that is an asset of the corporation", and accordingly refused to extend the principle in the Fraser case to find that loans made to a real estate company by its shareholder had the same character as if they had been incurred in connection with the business of that company. ...

Ernst & Young LLP, 2015 BCCA 445-- summary under Agency Summary Under Tax Topics- General Concepts- Agency presumption that law firm agreement binds client The appellant’s B.C. law firm retained Ernst & Young to provide her with U.S. tax advice in connection with negotiating a separation agreement with her husband. ...