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18 May 2017 Roundtable, 2017-0692331C6 - CLHIA 2017 Q3 - RCAs -- summary under Paragraph (c)

18 May 2017 Roundtable, 2017-0692331C6- CLHIA 2017 Q3- RCAs-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax- Paragraph (c) post-retirement benefits paid directly by the employer under a SERP did not generate refunds of the Part XI.3 tax paid in connection with the RCA trust established to pay related LC fees In connection with a supplemental executive retirement plan (the “Plan”), the Employer established a trust and made annual contributions to it so that the independent trustee could pay the annual fees for a letter of credit provided by a bank to pay the promised benefits in the event of the Employer’s bankruptcy. ... CRA responded: [A]n amount is not paid as a distribution under the RCA unless the amount is paid from property held in connection with the RCA. ...

Duthie Estate v. MNR, 92 DTC 1043, [1992] 1 CTC 2099 (TCC) -- summary under Start-Up and Close-Down Expenditures

Expense- Start-Up and Close-Down Expenditures Various fees including architectural fees and project planning fees paid by the taxpayer in connection with the proposed development of land as a luxury condominium development were incurred "for the purpose of creating a business entity" (p. 1050) and, therefore, on the authority of the Firestone case, were non-deductible capital expenditures. ...

Hanif's International Foods Ltd. v. The Queen, 2008 DTC 6630 (Alta. Prov. Ct.) -- summary under Subsection 241(3)

.)-- summary under Subsection 241(3) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(3) The provision of the Appellants' tax return to the Crown prosecutor in connection with a review as to whether the Appellants were suffering from financial hardship which should affect their sentencing for an offence committed by them under the Meat Inspection Act (Canada) was not authorized under s. 241(3)(a) as that statute dealt with regulatory offences rather than criminal offences. ...

Holm v. The Queen, 2003 DTC 755 (TCC) -- summary under Onus

" and then went on to indicate (at p. 760) that the assumptions in question were those that were made in connection with the assessment, not the confirmation. ...

Nesbitt Thomson Inc. v. MNR, 91 DTC 1113, [1991] 2 CTC 2352 (TCC) -- summary under Compensation Payments

MNR, 91 DTC 1113, [1991] 2 CTC 2352 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Lease inducement payments received by a holding company in connection with obtaining leases of office space which it, in turn, would provide to its operating subsidiaries, were found to have been received by it on income account based on a finding that it entered into the leases as part of its day-to-day business operations. ...

Bankmont Realty Co. Ltd. v. National Capital Commission (1980), 19 L.C.R. 97 (FCA) -- summary under Improvements v. Repairs or Running Expense

They were a "capital expenditure incurred in connection with moving the business operation itself". ...

Ellis v. The Queen, 2007 DTC 996, 2007 TCC 289, aff'd 2008 DTC 6230, 2008 FCA 92 -- summary under Income-Producing Purpose

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. ...

Chabaud c. La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure) -- summary under Paragraph 56(1)(o)

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. ...

Glen v. The Queen, 2003 DTC 2109, 2003 TCC 807 (Informal Procedure) -- summary under Subparagraph 8(1)(i)(iii)

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. ...

Bell v. Canada, 2000 DTC 6365, 2008 FCA 51 (FCA) -- summary under Subsection 2(1)

Canada, 2000 DTC 6365, 2008 FCA 51 (FCA)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) The central management and control of a company, for purposes of assessing the degree of connection of employment income and dividends generated for native employees and a native shareholder, was found not to be situate on the reserve, notwithstanding the maintenance of a small office there, given that the shareholder and officer managed the company from wherever he was with the assistance of his accountant, who was situate off the reserve. ...

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