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MNR, 91 DTC 1286 (TCC)-- summary under Paragraph 212(4)(b) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(b) Beaubier J. affirmed the disallowance by the Minister of all but $100,000 per year of amounts paid by a Canadian subsidiary to its U.S. parent which allegedly were reimbursements of expenses incurred by the parent in connection with litigation involving the Canadian subsidiary, and for accounting, administrative and sales services, and for overheads, of the U.S. parent. ...

Expense- Start-Up and Close-Down Expenditures The taxpayer, which had a 25% interest in an oil field under the North Sea, was not permitted to deduct a provision for the estimated costs to be incurred at a future date, on completion of production, in order to: restore to their original condition rigs and tankers that it had leased and adapted for use in connection with extracting or transporting the oil; removing a manifold, loading lines and buoy from the area; and capping wells and removing well heads. ...

The Queen, 2006 DTC 3431, 2006 TCC 347, aff'd supra 2008 DTC 6017, 2007 FCA 370-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) appreciation in warrants allocated to employees on capital account The taxpayer's employer ("Canaccord"- a broker dealer) was issued broker compensation warrants in connection with an equity treasury financing by a Canaccord client, and Canaccord allocated a portion of those warrants to the taxpayer as compensation for his employment services. ...

.)-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege The TD Bank sued a corporation for negligent misrepresentation with respect to a comfort letter received in connection with a $40.5 million loan to the corporation's subsidiary. ...

There was evidence that the taxpayer's farming operations resulted in connections that enhanced the profitability of his law practice and that "his day to day life involved both, and the contacts he made in farming became valuable to his law practice". ...

(a) of the definition of "commercial activity" – nor was there any evidence that the sale was connected to any existing commercial activity of NM (including any connection which could engage ss. 141.1(1)(a) and (2)(a).) ...

A.G. of Canada, 2015 QCCA 837-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission thin cap issues were not considered at time of paying a dividend The appellant, which was a wholly-owned Ontario subsidiary of a Quebec corporation ("CTI"), paid a $136 million dividend to CTI in connection with a "Quebec shuffle" transaction. ...

In finding that this purchase by Sweet represented a purchase by a person with whom the Foundation dealt at arm's length for purposes of s.118.1(18), Evans, J.A. stated (at para. 48) that "the fact that it may seem that a transaction has been entered into largely as a favour by one party to the other does not necessarily mean that it cannot be at arm's length" and noted that while the taxpayer exercised a degree of influence over the nephew by virtue of their family relationship and business connections, Sweet was not entirely dependant on the taxpayer for its business, so that the Trial Judge did not commit any reversible error in this regard. ...

MNR, 65 DTC 5138, [1965] CTC 225 (Ex Ct), briefly aff'd 67 DTC 5196 (SCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) In connection with a rights offering the taxpayer, in addition to paying a commission to the underwriters in consideration for their services as dealers in securities, paid a fee for their services rendered in forming and managing a soliciting dealers group and in consideration for their agreement to maintain an orderly market, and paid a further fee which was alleged to be for the administrative and clerical services of the dealers in processing the rights tendered by shareholders, but which was described in the relevant agreement as a commission for each common share which a soliciting dealer procured. ...

In reaching this conclusion, Cullen J. stated (at p. 5088) that "generally speaking, a management or administration fee is an amount paid in respect of managerial services in connection with the direction or supervision of business activities," quoted approvingly a similar statement in IT-468, and then stated: [I]t is undisputed that Per Cundill made all the investment decisions. ...