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., 2015 QCCA 838, aff'd 2016 SCC 55-- summary under Foreign Accrual Property Income Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Accrual Property Income FAPI from loan by CFA to Canco The taxpayer implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. sub, that overlooked FAPI considerations – so that interest on a loan made by the sub back to Canada was included in the taxpayer's income. ...

Profit- Patents and Know-How The taxpayer, which had acquired letters patent relating to a galvanizing process, granted to a manufacturer of ammunition boxes a licence to use the process within the United Kingdom to manufacture up to 75,000 ammunition boxes for a period of up to approximately 12 years, in consideration for a "capital sum" of £3,000 and a royalty of 3d. per box. ...

The refusal of the Halifax office director to grant the waiver was remitted for consideration on the basis that he had rigidly applied the specific criteria in IC 92-2 and had misapprehended some of the facts (e.g., finding that the taxpayer had incurred additional consumer debt). ...

In finding that this fee was part of the consideration for the zero-rated vacation package, Dussault TCJ. noted (at p. 28-10) that "if one concludes that there is a supply separate from the supply of the vacation package it must be of 'a useful article or service'" and that, here, the alleged benefits attached to membership "represent nothing more than promotional literature used by Club Med for marketing its vacation packages at Club villages abroad" (p. 28-11). ...

MNR, 93 DTC 1266 (TCC)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments Lease inducement payments received by the taxpayer were taxable to it given that they were found not to have been intended as reimbursements for the cost of tangible personal property but, rather, as consideration for the taxpayer becoming subject to an ongoing obligation to pay (deductible) rent, and given that the negotiation of leases was an important part of the taxpayer's business. ...

McGuckian, [1997] BTC 343 (HL)-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments On 23 November 1979, the trustee who owned shares of a private company ("Ballinamore") assigned to a UK company the right to any dividend payable by Ballinamore in 1979 for consideration that was equal to 99% of the dividend that in fact was declared and paid by four days later. ...

.)-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 mere suspicion An investigation by CCRA of the taxpayer was not transmuted into a criminal investigation until the auditor met with Special Investigations and referred the file to them for their consideration. ...

.)-- summary under Subsection 231.1(1) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1) An investigation by CCRA of the taxpayer was not transmuted into a criminal investigation until the auditor met with Special Investigations and referred the file to them for their consideration. ...

The Queen, 97 DTC 12107 (TCC)-- summary under Distribution Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Distribution cash and equipment not single property type A transaction in which the common shares of a corporation held by the taxpayer were purchased for cancellation for consideration consisting of equipment and cash did not qualify under former s. 55(3)(b) given that the cash and equipment could not be regarded as a single type of property for purposes of that provision and given that it was the parties' intention that the taxpayer receive more than its proportionate share of the equipment of the corporation. ...

The partnership, therefore, was terminated when the mining claims were transferred to a company in consideration for shares. ...