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The Queen, 2007 DTC 996, 2007 TCC 289, aff'd 2008 DTC 6230, 2008 FCA 92-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose A fee paid by the taxpayer to Ernst & Young LLP for advice in connection with strategizing as to how to monetize his shares through a forward exchange contract were not incurred to assist him in gaining or producing income from the shares and, therefore, were not deductible. ...

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Paragraph 56(1)(o) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(o) 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 not research "grants" (which had been judicially defined as financial assistance) because they instead represented consideration for (employment) services rendered by the taxpayer. ...

The Queen, 2003 DTC 2109, 2003 TCC 807 (Informal Procedure)-- summary under Subparagraph 8(1)(i)(iii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(iii) The cost of software that the taxpayer purchased for use in connection with his part-time teaching duties was deductible. ...

The Queen, 2005 DTC 959, 2005 TCC 335-- summary under Price Adjustment Clause Summary Under Tax Topics- General Concepts- Price Adjustment Clause The existence of an "anti-flip agreement" allegedly given by the taxpayer in connection with its purchase of shares (under which it would pay to the vendor any consideration received by it, on a subsequent sale by it of the shares, over and above the purchase price) was found not to be supported by the evidence. ...

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. ...

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, 2010 DTC 1018 [at at 2624], 2009 TCC 440 (Informal Procedure)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) The taxpayer, who had been a resident of Canada for six years, moved to a job in Saudi Arabia for the three taxation years in question, with most of his salary being remitted to his family who stayed in Canada and with the taxpayer returning to Canada for 30 vacation days a year and maintaining various other connections with Canada. ...

The Queen, 2012 TCC 105-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...

The Queen, 2012 TCC 105-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...