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The Queen, 2012 DTC 1190 [at at 3488], 2012 TCC 212 (Informal Procedure)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) dominant character of payments made to post-doctoral fellow was compensation for research work The taxpayer sought an exemption under s. 56(1)(n) in respect of income from the Ontario Health Research Institute ("OHRI") in connection with a postdoctoral fellowship at the University of Ottawa. ...

., 99 DTC 5358, [1999] 3 CTC 520 (FCA)-- summary under Subsection 93(1) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(1) s. 93 deeming a dividend in kind of a note to be a dividend received precluded a subsequent bad debt claim for the note In connection with the liquidation of a U.S. corporation owned by the two Canadian corporate taxpayers, they received promissory notes owing by another U.S. corporation and cash, and elected under s. 93(1) in respect to the distribution. ...

In connection with matrimonial litigation, the Class A share of the appellant was found to have a fair value of $150,000 rather than the $10,000 figure advanced by the appellant, in light of its entitlement to 1/2 the net property on a winding-up and in light of the entitlement of a holder of that share to hire himself as a manager of the farm and pay himself reasonable remuneration for its services, without fear of being dismissed and without the obligation to consult or take instructions from anyone. ...

A proposed structure on a site which it planned to rent to tenants was therefore intended to be used in connection with its business, i.e., renting out a property is a "use" of property. ...

., 64 DTC 5184, [1964] CTC 294 (Ex Ct)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) no "conferral" if corporation is advancing its business In 1953 two subsidiaries of the taxpayer waived the interest that was coming due on two loans they had made to the taxpayer a year previously, and a year later all the further interest was waived in connection with the repayment by the taxpayer of a portion of the principal in full satisfaction of the loans. ...

In finding that there have been no misrepresentation by the taxpayer in connection with not including these amounts in his income, Mr. ...

In finding that B.V. was carrying on an active business, MacKay J. noted that the investing activities of B.V. were within the scope of the objectives set out in its articles of incorporation, supervising managing directors of B.V. met on a quarterly basis, B.V. through its supervisory director had investigated making other acquisitions in addition to those that it actually made, it used staff resources provided by affiliated companies in Amsterdam in connection with receiving and accounting for payments made on the note, and indicated that it was not appropriate for the Minister's reassessment not to relate to the whole of the income of B.V. so that the concession of the Minister that interest on the loan was from an active business assisted the taxpayer's position. ...

The taxpayer claimed input tax credits on expenses relating to the operation of a private jet, which were incurred primarily in connection with Mr. ...

C Miller J found that an obiter dictum in O'Dwyer, dealing with a similar issue in connection with a s. 237.1(7.4) penalty, was apt (para. 27, citing O'Dwyer at para. 31): [S]imply reiterating the multiple combinations of possibilities that could result in the imposition of the penalty does not tell a taxpayer what specific act (that would result in the imposition of the penalty) he or she is alleged to have committed. ...

Although the Canadian agents issued "conditional receipts" in Canada providing temporary insurance, the policies which the taxpayer ultimately issued in the United States following the completion of the underwriting process stated that the final contract and the application (in connection with which the conditional receipts were issued) were one entire contract, and it was clear that those contracts were concluded in the United States rather than in Canada. ...