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Repairs or Running Expense The taxpayer paid $480,900 to the City of Montreal in connection with a land exchange with the City and relocating a city street further to the north. ...

The Queen, docket 2000-612-- summary under Subsection 260(1) Summary Under Tax Topics- Excise Tax Act- Section 260- Subsection 260(1) A charity that purchased various components, assembled them into solar-powered, fixed-tuned radios, and exported the radios for use in connection with evangelical activities in third-world countries was not eligible for the rebate under s. 260(1) because the property that was supplied to it (radio components) was not the same property that was exported by it (radios). ...

.)-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) The written assignment by the Netherlands judgment creditor of an insolvent company of debt for a nominal amount to the taxpayer and the other shareholder of the company was an acquisition "by way of a bargain made at arm's length" for purposes of s.29A(1) of the Capital Gains Tax Act 1979 given that the taxpayer had no relevant connection with the creditor. ...

These amounts were non-deductible given the inability of the taxpayer to establish some connection between the earning of income and the payment of the fees. ...

Canada, 2003 DTC 5723, 2003 FCA 433-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 The employment income earned by Indian employees residing in the National Capital Region and working for the Department of Indian Affairs and Northern Development in jobs relating to Aboriginal issues did not have a sufficient connection to a reserve to justify a conclusion that their income was located on a reserve. ...

MNR, 90 DTC 1646, [1990] 2 CTC 2132 (TCC)-- 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 expenses incurred by an estate with an extensive portfolio of investments in connection with obtaining probate; determining the extent of the entitlement of various beneficiaries; managing and supervising the investments; devising and carrying out plans to minimize taxation of the estate, beneficiaries and companies within the group; and investing in liquid assets; were non-deductible. ...

MNR, 91 DTC 1079, [1991] 2 CTC 2121 (TCC)-- summary under Section 34 Summary Under Tax Topics- Income Tax Act- Section 34 Lamarre Proulx J. rejected a submission that under the laws of Ontario interim accounts rendered by a solicitor are not enforceable and, in any event, found that the statements of account rendered in connection with the taxpayer's law practice were not worded so as to constitute true interim bills of account. ...

The Queen, 95 DTC 5376, [1995] 2 CTC 157 (FCTD)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs The taxpayer commenced to use personal-use capital property in connection with a real estate development business at the time he made a decision to proceed with the development of the property as a condominium project and retained architects, project managers and other professionals to assist with the development plans. ...

MNR, 2003 DTC 5054 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus Before going on to find that the Minister had failed to establish that he had issued requirements under s. 231.2(1) for a disclosure of the names of third parties only in connection with his audit of the corporate applicant rather than in relation to the third parties, Heneghan J. stated (at p. 5065) that: "The Minister, not the taxpayer, bears the burden of complying with section 231.2. ...

The Queen, 2009 DTC 1087, 2009 DTC 1201-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 The taxpayer, who was a status Indian, was not exempt on the profits of his logging business given that the logging operations were carried on exclusively off the Reserve (although bookkeeping was done by him and an assistant on the Reserve) and the logs were transported by truck directly to the off-Reserve customers without (except in rare instances) entering onto the Reserve, and given that this was not a business that had any historical, social or cultural connection to the Reserve. ...