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“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ...

In finding that the taxpayer was resident in Ontario for his 2017 to 2019 taxation years, the ones assessed by the ARQ, Bourgeois JCQ indicated that: the taxpayer had Ontario rather than Quebec health insurance and had an Ontario driver's license. although he would stay at a condominium in Montreal, these were only temporary stays in connection with the supervision of Montreal properties, and the condo was not used as a personal residence. the place which he considered to be his home was his Ontario farm; and his days each year in Quebec were mere sojourning for the purpose of attending to his rental investments and using his vacation properties there. ...

The King, 2025 TCC 93 (Informal Procedure)-- summary under Subsection 56.1(4) Summary Under Tax Topics- Income Tax Act- Section 56.1- Subsection 56.1(4) Tax Court did not have the power to infer an allocation of a court order for support between child and spousal support The separation agreement entered into between the taxpayer and his wife in connection with their separation in December 2010 provided for him to pay $2,500 per month in child support and $3,500 per month in spousal support. ...

PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86, aff'd [2025] HCA 30-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the “Bottler”) pursuant to which an Australian subsidiary of PepsiCo (the “Seller”) sold concentrate to the Bottler and PepsiCo granted the Bottler the right to use the Pepsi and Mountain Dew trademarks in connection with its sales of the soft drinks. ...

The Queen, docket 98-2383(IT)G (TCC)-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) GAAR not to be used to fill in gaps of specific anti-avoidance provisions The taxpayer, who owned a portion of the shares of the holding ("GH") which, in turn, owned an operating company ("GBC") utilized the enhanced capital gains exemption in connection with the sale of a cement plant operated by GBC through the following transactions: the taxpayer and the other shareholders of GH transferred a portion of their shares of Holdings to a newly-incorporated company ("Newco") in consideration for shares of Newco having a value of $500,000; GBC paid a dividend-in-kind of most of the cement plant assets (having a value of $1 million) to Holdings; Holdings redeemed the common shares held in its capital by Newco by transferring to Newco the assets it had received from GBC; and the shareholders of Newco's sold their interests in Newco to the purchaser (who also purchased the remaining cement-plant assets directly from GBC). ...

Canada, 2010 DTC 5172 [at at 7304], 2010 FCA 280-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) settler did not intend to lose control of "contributed" property A purported Barbados trust that was used in connection with a tax plan to avoid Canadian capital gains tax on the disposition of shares of a corporation was found not to exist at the time of a purported sale of shares by the purported trust given that the settler never intended to lose control of the shares to the Barbados trustee or of the money resulting from their sale, he did not sign the trust deed until after the sale of the shares to the third party, and the shares were not validly transferred to the trust (and, in fact, at the relevant time, they could not be so transferred because they were subject to the security interest of a third party). ...

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) Archambault J. found that "bursary" amounts that the taxpayer received from the University of Laval in connection with his postdoctoral fellowship at that university were employment income rather than amounts described under s. 56(1)(n), because his work was in the nature of "employment" under Quebec civil law. ...

The Queen, 2011 DTC 1163 [at at 873], 2011 TCC 213-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure The taxpayer incurred legal and accounting fees in 1997 and 1998 of approximately $1.9 million in connection with a complicated reorganization of the manner in which it financed its investment in its US subsidiaries. ...

The Queen, 2011 DTC 1052 [at at 272], 2011 TCC 22-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 view to post-dissolution profit In connection with a limited partnership offering whose final closing was on December 31, 1993, the taxpayer bought units in the partnership for $18,000 and 18 common shares in a corporation for a dollar each. ...

The Queen, 2005 TCC 92-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business litigation support services provided by trustee for bankrupt financial institution were an "undertaking" The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ...