Cases
Leonard v. The Queen, 2021 TCC 33
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss - Debt | loss on mortgage that was acquired in order to acquire the underlying property under foreclosure proceeding on income account was also from an adventure | 347 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | Court not bound by an erroneous admission by one of the parties | 115 |
| Tax Topics - Income Tax Act - Section 9 - Timing | cost of mortgage debt acquired as adventure not deductible when expended | 53 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | foreclosure proceedings resulted in disposition of the mortgage but not of the debt it had previously secured | 471 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(i) | on a foreclosure, the taxpayer disposed of his mortgage, even though the debt it secured remained outstanding | 429 |
Deyab v. Canada, 2020 FCA 222
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | neglect in not maintaining a shareholder’s account | 247 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | although the taxpayer had been negligent, conduct verging on intentional acting not established | 338 |
Deputy Commissioner of Taxation v Rennie Produce (Aust) Pty Ltd (in liq), [2018] FCAFC 38
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| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | third-party documents obtained in commercial judicial proceedings were producible under a requirement issued by the tax authority | 405 |
Olympia Trust Company v. Canada, 2015 FCA 279
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| Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) | RRSP trustee, not annuitant, was the "purchaser" | 200 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | fictitious s. 104(2) trust is not the purchaser | 118 |
Samaroo v. CRA, 2014 DTC 5096 [at 7137], 2014 BCSC 1349
R. v. Eddy, 2014 DTC 5050 [at 6780], 2014 ABQB 164
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| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) | reasonable limits on Crown obligations to disclose evidence to accused | 261 |
Sattva Capital Corp. v. Creston Moly Corp., 2014 SCC 53, [2014] 2 S.C.R. 633
R. v. McCartie, 2013 DTC 5136, 2013 BCPC 289
Madison v. Canada, 2012 DTC 5072 [at 6935], 2012 FCA 80
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| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(2) - Paragraph 227.1(2)(b) | 126 |
House v. Canada, 2011 DTC 5142 [at 6131], 2011 FCA 234
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| Tax Topics - General Concepts - Onus | overall burden on the taxpayer | 148 |
Syrek v. Canada, 2009 DTC 5767, 2009 FCA 53
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Canada v. General Motors of Canada Ltd., 2008 DTC 6381, 2008 FCA 142
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 96 |
Canada v. 1524994 Ontario Limited, 2007 FCA 74
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | agreements respected for supply determination purposes | 215 |
| Tax Topics - General Concepts - Agency | alleged principal lacked capacity to collect OHIP fees | 262 |
Ventas Inc. v. Sunrise Senior Living Real Estate Investment Trust, 2007 ONCA 205
R. v. Larsen, 2006 DTC 6574, 2005 BCSC 1867 (BCSC)
Bernick v. Canada, 2004 DTC 6409, 2004 FCA 191
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| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | cost of bonds equal to their FMV | 139 |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | accounting method must produce an accurate result | 179 |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 179 |
Brown v. Canada, 2003 DTC 5298, 2003 FCA 192 (FCA)
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| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | time of structuring is the relevant time | 139 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(g) | 110 | |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.2) - Paragraph 96(2.2)(d) | 135 | |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.4) - Paragraph 96(2.4)(b) | 109 |
Lecours v. The Queen, 2003 DTC 5009, 2002 FCA 5 (FCA)
Selmeci v. The Queen, 2002 DTC 7186, 2002 FCA 293 (FCA)
Canada v. Canadian Helicopters Ltd., 2002 DTC 6805, 2002 FCA 30
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | indirect eligible use | 135 |
Harris v. The Queen, 2002 DTC 149 (FCTD)
Bell v. Canada, 2002 DTC 6780, 2002 FCA 7
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 178 |
Trzop v. Canada, 2002 DTC 6728, 2001 FCA 380
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(4.1) | 94 | |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | no addition for unpaid labour | 68 |
Vancouver Art Metal Works Ltd. v. The Queen, 2001 DTC 5337, 2001 FCT 265 (FCTD)
James v. Canada, 2001 DTC 5075 (FCA)
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| Tax Topics - General Concepts - Audit Procedure | 101 | |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | vacating not a remedy for lack of due dispatch | 86 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | no s. 56(2) inclusion to taxpayer if recipient of the transferred property had earned it rather than the taxpayer | 332 |
Argus Holdings Ltd. v. The Queen, 2001 DTC 6681 (FCA)
Backman v. The Queen, 99 DTC 5602 (FCA), aff'd 2001 DTC 5149 (SCC)
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336
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Timmins v. The Queen, 96 DTC 6378 (FCTD)
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| Tax Topics - Income Tax Act - Section 122.3 - Subsection 122.3(1) | 175 |
Bertram v. The Queen, 96 DTC 6034 (FCA)
MCA Television Ltd. v. The Queen, 94 DTC 6375 (FCTD)
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Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40
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Sidhu v. MNR, 93 DTC 5453 (FCA)
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| Tax Topics - Income Tax Act - Section 230 - Subsection 230(1) | 77 |
The Queen v. Old HW-GW Ltd., 93 DTC 5199 (FCA)
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| Tax Topics - Statutory Interpretation - Context | 39 |
Urichuk v. The Queen, 93 DTC 5120 (FCA)
R. v. Castelli, 92 DTC 6556 (Ont. Ct. GD)
Stowe-Woodward Inc. v. The Queen, 92 DTC 6149 (FCTD)
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | 50 |
Edward Bowes v. Minister of National Revenue, 91 D.T.C 5310, [1991] 1 CTC 68 (FCTD)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 56 |
The Queen v. Betterest Vinyl Manufacturing Ltd., [1990] 2 CTC 292 (BCCA)
Wil Mechanical Ltd. v. The Queen, 90 DTC 6475 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | subcontractors entitled to holdback amounts | 83 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 83 |
Border Chemical Co. Ltd. v. The Queen, 87 DTC 5391, [1987] 2 CTC 183 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 78 |
The Queen v. Gorjup, 87 DTC 5348, [1987] 2 CTC 129 (FCTD)
Phyllis Moore v. The Queen, 87 DTC 5217 (FCTD)
Moore v. The Queen, 87 DTC 5215 (FCA)
Magilb Development Corp. Ltd. v. The Queen, 87 DTC 5012, [1987] 1 CTC 66 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | tentative overtures for subdivision did not effect a change in use | 107 |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | preliminary overtures for approval of housing development of farm did not convert to inventory | 208 |
The Queen v. Capitol Life Insurance Co., 86 DTC 6164, [1986] 1 CTC 388 (FCA)
R. v. Marcoux, 85 DTC 5453, [1985] 2 CTC 254 (Alta. Prov. Ct.)
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| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | 3rd party seizure invalid | 49 |
Spencer v. R., 85 DTC 5446, [1985] 2 CTC 310 (SCC)
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| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 7 | 37 |
Armstrong v. The Queen, 85 DTC 5396 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | unexpected sale of race horse | 131 |
Burri v. The Queen, 85 DTC 5287, [1985] 2 CTC 42 (FCTD)
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| Tax Topics - Income Tax Act - Section 129 - Subsection 129(4) - Canadian Investment Income | apartment rentals were not from an active business | 82 |
W. Rudolph Construction Ltd. v. The Queen, 84 DTC 6454, [1984] CTC 457 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 90 |
Frankel v. The Queen, 84 DTC 6220, [1984] CTC 259 (FCTD)
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| Tax Topics - Income Tax Act - Section 222 | 68 |
Lipsey v. MNR, 84 DTC 6192, [1984] CTC 208 (FCTD)
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| Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) | 79 |
Stephens v. The Queen, 84 DTC 6169 (FCTD)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 319(1) | 63 |
Greiner v. The Queen, 84 DTC 6073, [1984] CTC 92 (FCA)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | "otherwise disposed of" includes extinguishment on surrender | 85 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 201 |
Bouchard v. The Queen, 83 DTC 5193, [1983] CTC 173 (FCTD)
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Riviera Hotel Co. Ltd. v. The Queen, 82 DTC 6045, [1982] CTC 30 (FCTD)
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| Tax Topics - Income Tax Act - Section 129 - Subsection 129(4) - Canadian Investment Income | 88 |
Carruthers v. The Queen, 82 DTC 6009, [1982] CTC 5 (FCTD)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 465(15) | 55 | |
| Tax Topics - General Concepts - Fair Market Value - Shares | 248 |
Don Fell Ltd. v. The Queen, 81 DTC 5282, [1981] CTC 363 (FCTD)
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| Tax Topics - General Concepts - Purpose/Intention | 24 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 87 |
Honeywood Ltd. v. The Queen, 81 DTC 5066, [1981] CTC 38 (FCTD)
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| Tax Topics - Income Tax Act - Section 256 - Subsection 256(2.1) | 53 |
Sandhu v. The Queen, 80 DTC 6097, [1980] CTC 158 (FCTD)
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| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | partner carries on partnership business | 19 |
| Tax Topics - Income Tax Act - Section 96 | 62 |
Vanguard Trailers Ltd. v. The Queen, 80 DTC 6001, [1980] CTC 42 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages | 54 |
The Queen, v. Leclerc, 79 DTC 5440, [1979] CTC 527 (FCTD)
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| Tax Topics - Income Tax Act - Section 68 | 71 |
Hummel Corp. of Quebec Ltd. v. The Queen, 79 DTC 5426, [1979] CTC 483 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 51 |
Pepsi-Cola Canada Ltd. v. The Queen, 79 DTC 5387, [1979] CTC 454 (FCA)
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| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital | 103 |
Gahrns v. The Queen, 78 DTC 6436, [1978] CTC 651 (FCTD)
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 29 |
Atinco Paper Products Ltd. v. The Queen, 78 DTC 6387, [1978] CTC 566 (FCA)
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| Tax Topics - General Concepts - Tax Avoidance | 58 | |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 69 |
Wardean Drilling Co. Ltd. v. M.N.R., 78 DTC 6202, [1978] CTC 270 (FCTD)
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| Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Principal-Business Corporation | 65 | |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(6) | 129 |
Dobell v. The Queen, 77 DTC 5316, [1977] CTC 458 (FCTD)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 24 |
Darke v. MNR, 76 DTC 6468, [1976] CTC 734 (FCTD)
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The Queen v. Esskay Farms Ltd., 76 DTC 6010, [1976] CTC 24 (FCTD)
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|---|---|---|
| Tax Topics - General Concepts - Agency | weight given to written agreement terms in finding that intermediary purchased as principal | 122 |
| Tax Topics - General Concepts - Sham | no sham if documents describe intended legal rights | 354 |
| Tax Topics - General Concepts - Tax Avoidance | no sham if documents describe intended legal rights | 354 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 143 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | 199 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 57 | |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 195 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 58 |
Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)
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| Tax Topics - General Concepts - Fair Market Value - Shares | 50 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 72 |
David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD)
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| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 56 | |
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) | proceeds from the sale of cash-rich company to pension fund for wind-up 5 months later were "otherwise appropriated ... on the winding-up" | 321 |
Grant v. The Queen, 74 DTC 6252, [1974] CTC 332 (FCTD)
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| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | 64 |
The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)
MNR v. Beaupré Estate, 73 DTC 5255, [1973] CTC 316 (FCTD)
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(d) | 146 |
Weinberger v. MNR, 64 DTC 5060 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | cost of patent included legal costs and R&D | 63 |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(c) | 70 |
Meteor Homes Ltd. v. MNR, 61 DTC 1001, [1960] CTC 419 (Ex. Ct.)
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Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433
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| Tax Topics - Income Tax Act - Section 9 - Timing | 185 |
Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 52 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Deposits | 73 | |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 96 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | deposit excluded | 78 |
R. v. Snider, 54 DTC 1129, [1954] CTC 255 (SCC)
See Also
Logix Data Products Inc. v. The Queen, 2021 TCC 36
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | alleged SR&ED work was routine engineering | 184 |
Landbouwbedrijf Backx B.V. v. The Queen, 2021 TCC 2
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|---|---|---|
| Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(c) | no application because taxpayer became a Canadian resident prior to the property's acquisition | 246 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | Dutch legal expert testimony was required in order to establish dual corporate residency - and failure to engage competent authorities | 632 |
| Tax Topics - General Concepts - Estoppel | Minister not precluded from reassessing contrary to initial acceptance of non-residency in returns as filed | 109 |
Larkin v. The Queen, 2020 TCC 98 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | geologist with past successes but no current income was carrying on business | 294 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) | a geologist with no current income could deduct various expenses documented only in spreadsheets | 210 |
Anand v. The Queen, 2019 TCC 119
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Words and Phrases
parol evidence rule| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | agency arrangement found notwithstanding written contract terms given that taxpayer acted as a conduit | 203 |
Ellison v Sandini Pty Ltd, [2018] FCAFC 44
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Ownership | family court order requiring the transfer of a portion of a larger bloc of shares likely did not result in a change in their beneficial ownership as the shares likely were not fungible | 1019 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | family court order did not effect a change in beneficial ownership of a larger bloc of shares held by the original owner (and in any event, the order named the wrong person) | 768 |
| Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) - Paragraph 73(1)(b) | subjective belief of parties that family court orders were efficacious did establish that a share transfer to a spouse occurred “because of” them | 419 |
Rowntree v Commissioner of Taxation, [2018] FCA 182
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| Tax Topics - General Concepts - Evidence | contract must be evinced by documents or conduct |
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | loan or other contract can only be achieved explicitly or through being evinced by conduct | 434 |
CIT Group Securities (Canada) Inc. v. The Queen, 2016 TCC 163, 2017 TCC 86
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(l) - Subparagraph 95(2)(l)(iii) | regulated Barbados subsidiary which invested in corporate debt qualified under the s. 95(2)(l) exclusion for foreign banks | 767 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Bank | no requirement to be regulated as a bank | 243 |
Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent | 377 |
| Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(d) | s. 142(1)(d) only applies to a supply exclusively re real property | 632 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service | payment of condo operating expenses was a service | 211 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | single supply of covering all time share operating costs | 172 |
| Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) | GST collectible based on invoicing times | 79 |
| Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | objecting to quantum was sufficient particularity | 177 |
| Tax Topics - General Concepts - Ownership | beneficial owner did not transfer property risk | 183 |
Okoroze v. The Queen, 2015 DTC 1107 [at 627], 2015 TCC 64
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McCarthy v. The Queen, 2016 TCC 45
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Chaudhry v. The Queen, 2016 DTC 1030 [at 2721], 2016 TCC 28 (Informal Procedure)
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Advocate Gen. for Scotland v. Murray Group Holdings Ltd., [2015] CSIH 77, [2015] BTC 36 (Ct. of Ses. (Inner House, 2nd)), aff'd sub nomine RFC 2012 Plc (formerly The Rangers Football Club Plc) v Advocate General for Scotland (Scotland) [2017] UKSC 45
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | income derived from service is assessable even where agreed to be redirected to 3rd party | 329 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | Scottish and English trust concepts had similar practical effect | 90 |
Staltari v. The Queen, 2015 DTC 1130 [at 818], 2015 TCC 123
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | no business where no business organization | 167 |
| Tax Topics - Income Tax Act - Section 38 - Paragraph 38(a.2) | land donated in order to achieve tax benefit was still a gift to a qualified donee | 133 |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | exclusion of gains that are ordinary income | 149 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | secondary intention to develop land irrelevant if land donated instead | 500 |
George Weston Limited v. The Queen, 2015 TCC 42
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | cross-currency swap was a hedge notwithstanding no intention to sell underlying indirect U.S. asset | 445 |
Invesco Canada Ltd. v. The Queen, 2014 TCC 375
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | management fee distributions to large MFT unitholders | 169 |
| Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) | discounted management fees charged by manager to MFTs not grossed up by MFT distributions of the discounts to large unitholders | 326 |
Agnico-Eagle Mines Limited v. The Queen, 2015 DTC 1008 [at 43], 2014 TCC 324, aff'd 2016 FCA 130
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | U.S. dollar principal of a convertible debenture should be considered on conversion to have been settled at the historical exchange rate when the conversion price was set | 542 |
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) | U.S. dollar principal of a convertible debenture should be considered on conversion to have been settled at the historical exchange rate when the conversion price was set |
Daimsis v. The Queen, 2014 DTC 1118 [at 3273], 2014 TCC 118 (Informal Procedure)
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Henco Industries Limited v. The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Land | deference to taxpayer's figure within appraiser's range of values | 111 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | compensation received in course of business but not in course of earning income | 192 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital | payment to withdraw from business was not an eligible capital amount | 146 |
| Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) | land ceased to be inventory through sterilization rather than business cessation | 184 |
| Tax Topics - Income Tax Act - Section 3 | compensation payment for destroyed business was non-taxable | 171 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | compensation payment for destroyed business was non-taxable | 171 |
Bolton Steel Tube Co. Ltd. v. The Queen, 2014 DTC 1102 [at 3202], 2014 TCC 94
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | reassessment to add fictitious income was void | 336 |
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(3) | s. 169(3) reassessment cannot increase quantum of previous assessment | 210 |
Vine Estate v. The Queen, 2014 DTC 1088 [at 3130], 2014 TCC 64
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Fair Market Value - Land | rent-controlled apartment | 102 |
Roszko v. The Queen, 2014 DTC 1083 [at 3099], 2014 TCC 59
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | contractual payments derived from fraud v. contract itself is a fraud | 133 |
Cameco Corporation v. The Queen, 2014 TCC 45
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | appeals from superceded reassessments were nullities | 56 |
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | basis for claim not disclosed | 119 |
McKesson Canada Corporation v. The Queen, 2014 DTC 1040 [at 2723], 2013 TCC 404
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Purpose/Intention | tax purpose v. commercial result | 92 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | terms adjusted within framework of transaction chosen by taxpayer | 928 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) | advocacy 3rd-party report not read by taxpayer | 163 |
| Tax Topics - Treaties - Income Tax Conventions - Article 9 | 5-year limitation did not apply to secondary Part XIII assessment | 206 |
Lee v. The Queen, 2013 DTC 1227 [at 1248], 2013 TCC 289
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Pièces automobiles Lecavalier Inc. v. The Queen, 2014 DTC 1126 [at 3319], 2013 TCC 310
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | debt-paydown transactions were avoidance transactions | 268 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | avoidance of debt forgiveness rules was abusive | 277 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | debt-paydown transactions effected in contemplation of sale transaction were part of same series as the sales transactions | 248 |
Harvey v. The Queen, 2013 TCC 298
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | guilty plea is prima facie proof of income from tax evasion | 111 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | deduction based on authorized use | 109 |
Last v. The Queen, 2012 DTC 1290 [at 3895], 2012 TCC 352
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(3) | 117 |
Raposo v. The Queen, 2013 DTC 1216 [at 1199], 2013 TCC 265
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | guilty plea prima facie proof of income from fraud | 193 |
River Hills Ranch Ltd. v. The Queen, 2013 DTC 1200 [at 1064], 2013 TCC 248
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | payments styled as herd expense reimbursements in substance were capital receipts for destruction of business and were proceeds of the related agreements | 296 |
Rahman v. The Queen, 2012 DTC 1270 [at 3799], 2012 TCC 320 (Informal Procedure)
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Kelly v. The Queen, 2012 DTC 1109 [at 3055], 2012 TCC 66
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | 252 | |
| Tax Topics - Statutory Interpretation - Business Judgment | 101 |
Hafizy v. The Queen, 2012 DTC 1093 [at 2943], 2012 TCC 56, aff'd 2014 FCA 109
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Zaki v. The Queen, 2011 DTC 1004 [at 18], 2010 TCC 606 (Informal Procedure)
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On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at 4243], 2010 TCC 475
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 44 | |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 121 |
Cirone v. The Queen, 2010 DTC 1103 [at 3034], 2010 TCC 137
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) | 134 |
Suzanne Sterling-Ross v. The Queen, 2009 DTC 1892, 2009 TCC 525 (Informal Procedure)
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Ollivierre v. The Queen, 2009 DTC 1796, 2009 TCC 490 (Informal Procedure)
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Witt v. The Queen, 2008 DTC 4322, 2008 TCC 407
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | 296 |
Klaboe v. The Queen, 2007 TCC 239
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Corpor-Air Inc. v. The Queen, 2007 DTC 841, 2006 TCC 75
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) | 114 |
Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation | tie-breaking vote of 50% non-resident shareholder | 92 |
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) | 91 | |
| Tax Topics - Income Tax Act - Section 9 - Agency - Agency | 97 | |
| Tax Topics - General Concepts - Effective Date | retroactive agency agreement | 124 |
Benjamin v. The Queen, 2006 DTC 2265, 2006 TCC 69 (Informal Procedure)
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Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 71 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 41 |
Shahsavar v. The Queen, 2005 DTC 523, 2005 TCC 184
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Redrupp v. The Queen, 2004 DTC 3320, 2004 TCC 640
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Morley v. The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | 38 | |
| Tax Topics - General Concepts - Fair Market Value - Other | 98 | |
| Tax Topics - General Concepts - Onus | 100 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 177 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) - Paragraph 13(27)(d) | 88 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | non-arm's length terms | 109 |
| Tax Topics - Income Tax Act - Section 96 | start-up activities sufficient to constitute carrying on business in common | 112 |
VIH Logging Ltd v. The Queen, 2004 DTC 2090, 2003 TCC 732
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) | 83 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(14) | 81 |
Hewlett Packard (Canada) Ltd. v. The Queen, 2003 DTC 1324 (TCC), rev'd 2004 DTC 6498, 2004 FCA 240
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 267 | |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) | taking assets out of use not sufficient trigger | 145 |
McCoy v. The Queen, 2003 DTC 660, 2003 TCC 332
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Chomica v. The Queen, 2003 DTC 535 (TCC)
Petro-Canada v. The Queen, 2003 DTC 94 (TCC), aff'd supra.
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Other | 44 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | jointly-owned company did not deal at arm's length with its two shareholders acting in concert | 187 |
Aikman v. The Queen, 2002 DTC 6874 (FCA)
Imperial Oil Ltd. v. The Queen, 2002 DTC 1954 (TCC)
Hunter v. The Queen, 2001 DTC 907 (TCC) (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Transitional Provisions | 89 | |
| Tax Topics - Income Tax Act - Section 252 - Subsection 252(4) | 89 |
Mathew v. The Queen, 2001 DTC 742 (TCC)
Davidson v. The Queen, 99 DTC 933 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.4) - Paragraph 15(2.4)(f) | 138 |
Promex Group Inc. v. The Queen, 98 DTC 1588 (TCC)
Mihelakos v. The Queen, 97 DTC 1450 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(2) | 73 |
Telecomsyst Services Inc. v. The Queen, 97 DTC 684 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 46 |
Lay v. The Queen, 95 DTC 272 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 103 |
Kalousdian v. The Queen, 94 DTC 1722, [1994] 2 CTC 2127 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.4) | 173 |
Kamsel Leasing Inc. v. MNR, 93 DTC 250 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 156 |
C&E Commissioners v. Battersea Leisure Ltd., [1992] BTC 5011 (Q.B.)
United Color and Chemicals Ltd. v. MNR, 92 DTC 1259 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 27 |
Samra v. MNR, 92 DTC 1008 (TCC)
Savoidakis v. MNR, 91 DTC 1463 (TCC)
William G. Docherty v. Minister of National Revenue, 91 DTC 537, [1991] 1 CTC 2409 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) | 83 |
Village Inn Hotel Ltd. v. MNR, 91 DTC 145 (TCC)
Pallan v. MNR, 90 DTC 1102 (TCC)
Essex County Council v. Ellam, [1989] BTC 133 (CA)
Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | deduction of head office expenses | 137 |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | 211 |
Schouten v. MNR, 63 DTC 397 (TAB)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 131 |
Warsh & Co. Ltd. v. MNR, 62 DTC 247 (TAB)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | 159 |
Doughty v. Commissioner of Taxes, [1927] AC 327 (PC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | appreciated inventory transfer as part of business drop-down on capital account | 134 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Goodwill | 134 |
Administrative Policy
4 March 2008 External T.I. 2008-0267001E5 F - Crédit pour la condition physique des enfants
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