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The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6160 (FCA)

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Tax Topics - General Concepts - Accounting Principles 38

The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)

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Demeterio v. The Queen, 2011 DTC 1148 [at 788], 2011 TCC 192

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Sussex Square Apartments Ltd. v. The Queen, 99 DTC 443 (TCC), aff'd 2000 DTC 6548, Docket: A-40-99 (FCA)

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Anderson v. MNR, 72 DTC 1263, [1972] CTC 2318 (T.R.B.)

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Dartmouth Developments Ltd. v. MNR, 67 DTC 551, [1967] Tax A.B.C. 780

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6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance

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royalty
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Tax Topics - Income Tax Act - Section 9 - Timing lump sum irrevocable prepayment of contingent future royalties fully included 227

10 October 2014 APFF Roundtable, 2014-0538131C6 F - revenus d'achats intégrés

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) no reserve for extended use by purchasers of in-apps 130

2 April 2013 External T.I. 2013-0475571E5 - Life insurance

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25 March 1999 Memorandum 9828577

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Tax Topics - Income Tax Act - Section 9 - Timing 47

22 July 1992, T.I. 921908 (May 1993 Access Letter, p. 189, ¶C9-262)

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13 May 1992 Internal T.I. 7-921151 -

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5 July 1990 TI AC59710

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Tax Topics - General Concepts - Payment & Receipt 73

11 April 1990 T.I. AC58705 File 5-8705

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Tax Topics - Income Tax Act - Section 9 - Timing 122

IT-165R "Returnable Containers"

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Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 65

Articles

Larry F. Chapman, John M. Ulmer, "Canada", Tax Treatment of Hybrid Financial Instruments in Cross-Border Transactions, International Fiscal Association, Vol. LXXXVa, p. 207.

J. Frankovic, "The Taxation of 'Unearned Income'", Tax Topics, No. 1406, February 18, 1999.

Paragraph 12(1)(b) - Amounts receivable

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Canada v. Huang and Danczkay Ltd., 2000 DTC 6549, 2002 FCA 226

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La Capitale, Compagnie D'assurance Générale v. The Queen, 95 DTC 5587 (FCTD)

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The Queen v. Johnson & Johnson Inc., 94 DTC 6125 (FCA)

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Stevenson & Hunt Insurance Brokers Ltd. v. The Queen, 93 DTC 5125 (FCTD), briefly aff'd 98 DTC 6383 (FCA)

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Maritime Telegraph and Telephone Co., Ltd. v. The Queen, 92 DTC 6191 (FCA)

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West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Accounting Principles 109
Tax Topics - Income Tax Act - Section 9 - Timing estimated amount was income 133

West Hill Redevelopment Co. Ltd. v. The Queen, 91 DTC 5430 (FCTD)

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Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) not applicable where mortgages receivable were all on income account 145
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory 42

West Kootenay Power and Light Co. Ltd. v. The Queen, 91 DTC 5214 (FCTD), aff'd supra.

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The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)

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The Queen v. Timagami Financial Services Ltd., 82 DTC 6268, [1982] CTC 314 (FCA)

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Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)

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Minister of National Revenue v. Benaby Realties Limited, 67 DTC 5275, [1967] CTC 418, [1968] S.C.R. 12

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Tax Topics - Income Tax Act - Section 9 - Timing profits recognized when ascertained 79

MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)

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receivable
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Tax Topics - Income Tax Act - Section 9 - Timing 23

Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)

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MNR v. Burns, 58 DTC 1028 (Ex Ct), briefly aff'd 59 DTC 1328 (SCC)

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Supreme Steel Ltd. v. The Queen, 96 DTC 1430 (TCC)

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Outboard Marine Corp. of Canada Ltd. v. MNR, 90 DTC 1350 (TCC)

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Laurentide Rendering Inc. v. The Queen, 88 DTC 6331, [1988] 2 CTC 200 (FCA)

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Burrard Yarrows Corp. v. The Queen, 86 DTC 6459, [1986] 2 CTC 313 (FCTD), aff'd sub nomine Versatile Pacific Shipyards Inc. v. The Queen, 88 DTC 6352 (FCA)

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20 March 2013 Internal T.I. 2012-0463181I7 F - Revenu des entrepreneurs

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1994 A.P.F.F. Round Table, Q. 25

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Tax Topics - Income Tax Act - Section 9 - Timing 16

20 August 1992 Internal T.I. 5-921716 -

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22 August 1991 T.I. (Tax Window, No. 8, p. 11, ¶1407)

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 32

21 August 1991 T.I. (Tax Window, No. 8, p. 21, ¶1402)

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24 May 1991 T.I. (Tax Window, No. 3, p. 19, ¶1235)

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IT-479R, "Transactions in Securities", para. 28-32

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IT-170R "Sale of Property - When Included in Income Computation," August 25, 1980

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Articles

Tetreault, "Canadian Tax Aspects of Asset Securitization", 1992 Conference Report, pp.23:21-23:25.

Paragraph 12(1)(c) - Interest

Commentary

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Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at 7292], 2012 FCA 214

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Tax Topics - General Concepts - Onus testimony sufficient to "demolish" assumptions 149
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss loan made as investment in mining business 162
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) interest was bad as settlement proceeds not allocated to it 212

Bastien Estate v. Canada, 2011 DTC 5118 [at 6014], 2011 SCC 38, [2011] 2 S.C.R. 710

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Goulet v. The Queen, 2009 DTC 1875, 2009 TCC 127 (Informal Procedure), aff'd 2011 DTC 5138 [at 6120], 2011 FCA 164

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Alepin v. The Queen, 79 DTC 5259 (FCTD)

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Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) payments applied first to interest 91

The Queen v. Elliott, 96 DTC 6189 (FCTD)

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(4) 62

The Queen v. Shaw, 93 DTC 5121 (C.A.)

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Piché v. MNR, 93 DTC 5295 (FCA)

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Miller v. The Queen, 85 DTC 5354, [1985] 2 CTC 139 (FCTD)

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Freeway Properties Inc. v The Queen, 85 DTC 5183, [1985] CTC 222 (FCTD)

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Salt v. The Queen, 84 DTC 6395, [1984] CTC 414 (FCTD)

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Perini Estate v. The Queen, 82 DTC 6080, [1982] CTC 74 (FCA)

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Tax Topics - General Concepts - Effective Date 175

The Queen v. Greenington Group Ltd., 79 DTC 5026, [1979] CTC 31 (FCTD)

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Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)

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in lieu of
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Tax Topics - General Concepts - Payment & Receipt interest coupons required to be presented 77

Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)

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Huston v. MNR, 61 DTC 1233, [1961] CTC 414 (Ex.Ct.)

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News Australia Holdings Pty Ltd v Commissioner of Taxation, [2017] FCA 645

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Pike v. Revenue and Customs Commissioners, [2014] BTC 33, [2014] EWCA Civ 824

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interest

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)

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Mackinnon v. The Queen, 2008 DTC 2052, 2007 TCC 658

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Boersen v. The Queen, 2007 DTC 1696, 2007 TCC 671 (Informal Procedure)

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Fleishman v. The Queen, 98 DTC 1836 (TCC) (Informal Procedure)

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Tax Topics - General Concepts - Payment & Receipt creditor may apply payment as it determines if debtor does not 95

Gestion Guy Ménard Inc. v. MNR, 93 DTC 1058 (TCC)

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Schaffer v. Cattermole, [1980] T.R. 331, 53 TC 499 (CA)

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Davies v. Premier Investment Co. Ltd.; Hewetson v. Carlyle (1945), 27 TC 27 (KBD)

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Lomax v. Peter Dixon & Son Ltd. (1943), 25 TC 353 (CA)

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CIR. v. Thomas Nelson & Sons, Ltd. (1938), 22 TC 176 (C.S. (1st Div'n))

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28 June 2017 External T.I. 2017-0705431E5 - funds held in settlement account

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Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(w) court-supervised settlement fund for class action was not required by a law 177
Tax Topics - Income Tax Act - Section 150 - Subsection 150(1.1) - Paragraph 150(1.1)(b) - Subparagraph 150(1.1)(b)(i) class-action settlement fund was required to file T3 returns 179

22 January 2014 External T.I. 2014-0517121E5 - T5 Information Slip Reporting Requirements

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5 October 2012 Roundtable, 2012-0453191C6 F - Investissements frauduleux

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IT-396R "Interest Income"

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Tax Topics - General Concepts - Effective Date 81

15 July 1998 T.I. 981358

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Tax Topics - General Concepts - Payment & Receipt issuance of bonds re accrued interest did not constitute payment thereof 56

16 May 1994 T.I. 940456

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 25

20 February 1992 T.I. 920074

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88 C.R. - F.Q.24

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86 C.R. - Q.69

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Marie-Eve Gosselin, Paul Lynch, "A Review of Interest Deductibility Since Ludco", 2015 CTF Annual Conference paper

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Lewis, "The Taxation of Structured Settlements", British Tax Review, 1994, No. 1, p. 19

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