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3 May 2002 External T.I. 2001-0110145 F - avantage imposable-vetements -- summary under Paragraph 6(1)(a)

3 May 2002 External T.I. 2001-0110145 F- avantage imposable-vetements-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursing a professor for a briefcase needed in connection with work would be non-taxable Where a professor is reimbursed by the university for the cost of a briefcase used to carry documents when travelling in connection with work, for example, giving lectures on behalf of the University, CCRA was generally prepared to accept that the payment was made primarily for the benefit of the employer, so that there would be no taxable benefit to the extent the amount was reasonable in the circumstances. ...

30 September 2002 Internal T.I. 2002-0152107 F - BRANCHEMENT A DES SERVICES PUBLICS -- summary under Paragraph 62(3)(g)

30 September 2002 Internal T.I. 2002-0152107 F- BRANCHEMENT A DES SERVICES PUBLICS-- summary under Paragraph 62(3)(g) Summary Under Tax Topics- Income Tax Act- Section 62- Subsection 62(3)- Paragraph 62(3)(g) utilities include cable, satellite TV and internet After finding that “utilities” referred to in s. 8(1)(c)(iii) did not extend to cable television services, satellite television services and internet connection services, the Directorate went on to note: [T]he expression "utilities" used in paragraph 62(3)(h) is broad enough to encompass telecommunications services such as cable television, satellite television and Internet connections. ...

Pelletier v. The Queen, 2009 DTC 1087, 2009 DTC 1201 -- summary under Section 87

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. ...

Osler, Hammond & Nanton Limited v. Minister of National Revenue, 63 DTC 1119, [1963] CTC 164, [1963] S.C.R. 432 -- summary under Shares

The taxpayer also realized a taxable gain when rights which it received in connection with the same shares were exercised by it and the shares acquired in exercise immediately sold by it. ...

Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA) -- summary under Class 10

The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)-- summary under Class 10 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10 Pipes and valves located between the inlet and outlet connections of the main pipeline and to and from the compressor station and metering facilities were integral parts of the compressor stations and metering facilities rather than integral parts of the pipeline and therefore were not described in paragraph 1(b). ...

Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA) -- summary under Class 2

The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)-- summary under Class 2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 2 Pipes and valves located between the inlet and outlet connections of the main pipeline and to and from the compressor station and metering facilities were integral parts of the compressor stations and metering facilities rather than integral parts of the pipeline and therefore were not described in paragraph 1(b). ...

Hull v. Wilson (1995), 128 DLR (4th) 403 (Alta. C.A.) -- summary under Paragraph 2(3)(b)

.)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) The only connection of the appellant with the State of Idaho was as a purchaser of goods there and as a party to an agreement with an Idaho manufacturer of trailers appointing the appellant as a distributor of trailers in Northern Alberta. ...

Clevite Development Ltd. v. MNR, 61 DTC 1093, [1961] CTC 147 (Ex. Ct.) -- summary under Business-Income Tax

.)-- summary under Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Business-Income Tax Royalties received by the taxpayer from foreign patents were found to be income from a business rather than income from the mere holding of property notwithstanding that the taxpayer apparently had no business operations at the relevant times because the patents had previously been held in connection with a manufacturing operation of the taxpayer and the licence agreement required the licensor to assist the licensee (although such assistance, in fact, was provided by the foreign parent of the taxpayer). ...

Clevite Development Ltd. v. MNR, 61 DTC 1093, [1961] CTC 147 (Ex. Ct.) -- summary under Start-Up and Liquidation Costs

.)-- 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 Royalty income of the taxpayer from foreign patents was found to be income from a business as opposed to a mere property holding notwithstanding that it had no business operations to speak of, because previously the patents had been held in connection with a manufacturing operation that the taxpayer had disposed of and because the licences required the taxpayer to assist the licensees (although, in fact, such support was provided by a foreign parent of the taxpayer). ...

Montreal Coke and Manufacturing Co. v. MNR, [1944] A.C. 126, [1944] CTC 94 (P.C.) -- summary under Paragraph 20(1)(c)

.)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) In connection with the retirement of old bonds and the issuance of replacement bonds, the taxpayer had to pay interest on both the old bonds and the new bonds for an overlapping period. ...

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