Search - connection

Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) The Court did not reverse a finding of the trial judge that an underwriting commission paid by the taxpayer to an investment dealer in connection with a public offering of treasury shares of the taxpayer by the investment dealer was for services of the underwriter including the analysis of the price and market possibilities, the bringing about of actual sales to the public on a widely-distributed basis, and administrative services. ...

La Reine, 2007 DTC 1534, 2007 TCC 461 (Informal Procedure)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition legal expenses incurred re cancellation of purchase may be loss from disposition Paris J. indicated, in obiter dicta at para. 22, that legal expenses incurred by the taxpayer in connection with her cancellation of a contract to purchase a building might have given rise to a capital loss on the basis that "the expenses may have been incurred as part of a disposition of the Appellant's right to purchase the building, and the disposition of that right may constitute a disposition of property within the meaning of section 38 and of the definition of 'property' set out in subsection 248(1) of the Act". ...

The Queen, 2005 DTC 1151, 2005 TCC 492, aff'd 2006 DTC 6447, 2006 FCA 216-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) An Air Canada pilot who took up residence in the Bahamas continued to be resident in Canada given that his work routine (which was centred on Pearson Airport) and family connections caused him to spend more than one-third of his time in Canada (during which time he would stay at his mother-in-law's apartment in Canada) and that he used a Canadian bank account for most of his banking. ...

The Queen, 2003 DTC 420, 2003 TCC 160 (TCC) (Informal Procedure)-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) travel between home office and school board meetings were in course of employment Travel allowances (calculated on a per-kilometre basis) received by the taxpayers in respect of their mandatory attendance at School Board meetings in connection with their duties of employment were not includable in their income given that they maintained offices in their homes, so that when they went from their home offices to the School Board premises they were engaged in carrying out their duties of a School Board member. ...

Expense- Start-Up and Close-Down Expenditures feasability study costs deductible The cost of engineering studies commissioned by the taxpayer (an operating hydro-electric company) to determine the feasibility of establishing hydro-electric facilities at various sites within its territory were found to be fully deductible given that its business required a continuous evaluation and appraisal of its power resources and its methods of operation; and expenditures incurred in this connection were part of its current operations. ...

Her Majesty The Queen, 90 DTC 6633, [1991] 1 CTC 86 (FCTD)-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business adventure involves isolated activity In finding that the taxpayer did not acquire two real estate properties in connection with an adventure in the nature of trade, Cullen J. stated (p. 6635): "An adventure in the nature of trade involves an isolated transaction only... ...

The Queen, 90 DTC 6142, [1990] 1 CTC 196 (FCTD), aff'd 94 DTC 6050 (FCA)-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Taxpayer's counsel unsuccessfully submitted that because the definition of "business" specifically excluded an office or employment, the Minister's assumption that the taxpayer had received employee stock options in connection with an adventure in the nature of trade could not stand. ...

Canada, 2016 FCA 19-- summary under Headings Summary Under Tax Topics- Statutory Interpretation- Headings heading did not contemplate illegal drugs In connection with finding (at para. 20) that the zero-rating in Sched. ...

ARQ, 2014 QCCQ 8444, partially aff'd 2018 QCCA 518-- summary under Section 313 Summary Under Tax Topics- Other Legislation/Constitution- Quebec- Business Corporations Act- Section 313 parent of dissolved corporation should have been assessed for its taxes Assessments by ARQ of the 2006 and 2007 years of a Quebec business corporation ("Wesdome") were invalid because Wesdome had been dissolved one day prior to the dates of the assessments in connection with completing its winding-up into its wholly-owning parent corporation. ...

., 2021 SCC 51, [2021] 3 S.C.R. 687-- summary under Certainty Summary Under Tax Topics- Statutory Interpretation- Certainty full effect should be given to Parliament’s precise and unequivocal words to produce certainty In connection with finding that the “business conducted” by a Barbados subsidiary of the taxpayer did not include its activities of raising capital from its shareholder (the taxpayer), Côté J stated (at para. 61, after having made the same point at greater length at para. 41): [I]f taxpayers are to act with any degree of certainty, then full effect should be given to Parliament’s precise and unequivocal words. ...