(c)-(r)

Paragraph 18(1)(c) - Limitation re exempt income

Administrative Policy

October 1999 TI 991667

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Cases

Industries Perron Inc. v. Canada, 2013 FCA 176

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De Graaf v. The Queen, 85 DTC 5280, [1985] 1 CTC 374 (FCTD)

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Canada v. General Motors of Canada Ltd., 2008 DTC 6381, 2008 FCA 142

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Tax Topics - General Concepts - Evidence parol evidence excluded 255

Canada v. McLarty, 2008 DTC 6354, 2008 SCC 26, [2008] 2 S.C.R. 79

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Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) decision making not subordinated to the other/structured arrangement 124
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (a) limited recourse promissory note 181

General Motors of Canada Ltd. v. Canada, 2004 DTC 6716, 2004 FCA 370

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Wawang Forest Products Ltd. v. The Queen, 2001 DTC 5212, 2001 FCA 80

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Ticketnet Corp. v. The Queen, 99 DTC 5409 (FCTD)

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Canadian Pacific Ltd. v. Minister of Revenue (Ontario), 99 DTC 5286, 41 OR (3d) 606 (Ont CA)

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B. Jolly Enterprises Ltd. v. The Queen, 94 DTC 6636 (FCA)

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The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607 (FCA)

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Wil Mechanical Ltd. v. The Queen, 90 DTC 6475 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 84
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing subcontractors entitled to holdback amounts 81

Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166 (FCA)

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Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153 (FCTD)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) no reserve for revenues collected at excess rate 96
Tax Topics - Income Tax Act - Section 9 - Timing future obligation for offsetting tariff reduction 106

TNT Canada Inc. v. The Queen, 88 DTC 6334, [1988] 2 CTC 91 (FCTD)

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Sears Canada Inc. v. The Queen, 86 DTC 6304, [1986] 2 CTC 80 (FCTD), aff'd 89 DTC 5039 (FCA)

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Northern and Central Gas Corp. Ltd. v. The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA)

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Consolidated-Bathurst Ltd. v. The Queen, 85 DTC 5120, [1985] 1 CTC 142 (FCTD), aff'd on different grounds, 87 DTC 5001, [1987] 1 CTC 55 (FCA)

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Amesbury Distributors Ltd. v. The Queen, 85 DTC 5076, [1984] CTC 667 (FCTD)

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Cummings v. The Queen, 81 DTC 5207, [1981] CTC 285 (FCA)

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McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 40

Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA)

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Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)

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The Queen v. Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)

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Mister Muffler Ltd. v. The Queen, 74 DTC 6615, [1974] CTC 813 (FCTD)

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The Queen v. Jawl Industries Ltd., 74 DTC 6133, [1974] CTC 147 (FCTD)

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J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC)

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Lawson v. Minister of National Revenue, 69 DTC 5155, [1969] CTC 201, [1969] S.C.R. 587

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Time Motors Limited v. Minister of National Revenue, 69 DTC 5149, [1969] CTC 190, [1969] S.C.R. 501

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Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)

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Tax Topics - Income Tax Act - Section 9 - Timing 296

See Also

Industries Perron Inc. (anciennement 3654419 Canada Inc.) v. The Queen, 2012 DTC 1072 [at 2836], 2011 TCC 433, aff'd 2013 FCA 176

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Fèdèration des Caisses Populaires Desjardins, 2000 DTC 1585 (TCC), rev'd on second (statutory contribution) issue 2002 DTC 7413 (FCA)

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Words and Phrases
provision reserve

Dibro Investments Ltd. v. MNR, 87 DTC 210 (TCC)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense liability incurred notwithstanding subsequently negotiated reduction 100

Barbican Properties Inc. v. The Queen, 97 DTC 122 (TCC), briefly aff'd 97 DTC 5008 (FCA)

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Alfred Dallaire Inc. v. MNR, 96 DTC 1094 (TCC)

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Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)

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Tax Topics - Income Tax Act - Section 9 - Timing 201

I.B. Pedersen Ltd. v. The Queen, 94 DTC 1085 (TCC)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) no deduction for future remediation work 53

Co-operator's General Insurance Co. v. MNR, 92 DTC 303 (TCC)

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Pioneer Designs Corp. v. MNR, 91 DTC 293 (TCC)

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Dunblane Estates Ltd. v. MNR, 89 DTC 137 (TCC)

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Southern Pacific Insurance Co. Ltd. v. C.I.R., [1986] BTC 181 (PC)

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Fred Nesbit Distributing Co. v. U.S., 85-2 USTC 89580 (D.C. Iowa)

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Canada Packers Ltd. v. MNR, 68 DTC 682 (TAB)

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Quebec Photo Service Inc. v. MNR, 67 DTC 315 (TAB)

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Acadia Overseas Freighters Halifax Ltd. v. MNR, 62 DTC 84 (TAB)

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Capital Transit Ltd. v. MNR, 52 DTC 287 (ITAB)

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J.J. Joubert Limité v. MNR, 52 DTC 317 (ITAB)

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Administrative Policy

S2-F1-C1 - Health and Welfare Trusts

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22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities

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Tax Topics - Income Tax Act - Section 9 - Computation of Profit financial liabilities not to be marked to market 128
Tax Topics - Income Tax Act - Section 9 - Timing liabilities not to be marked to market 128

11 April 2000 Internal T.I. 2000-000132 -

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Tax Topics - Income Tax Act - Section 9 - Computation of Profit 36

16 February 1999 T.I. 990053

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5 February 1996 T.I. 952844 (C.T.O. "Deductibility of Repayable Income Amounts")

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18 November 1992 Memorandum 921979 (September 1993 Access Letter, p. 407, ¶C9-286)

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30 November 1991 Round Table (4M0462), Q. 5.1 - Acquisition of a Business (C.T.O. September 1994)

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91 CPTJ - Q.16

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90 C.R. - Q14

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19 October 89 T.I. (March 1990 Access Letter, ¶1140)

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IT-215R "Reserves, Contingent Accounts and Sinking Funds"

IT-467R "Damages, Settlements and Similar Payments"

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Articles

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper

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Hirsch, "Real Estate Issues: Traps and Opportunities", 1995 Corporate Management Tax Conference Report, c. 9

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Holmes, "Supplemental Retirement Arrangements May Provide Deferral for Employee and Deduction for Employer", Taxation of Executive Compensation and Retirement, March 1990, p. 243

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Paragraph 18(1)(h) - Personal and living expenses

Cases

Scott v. Canada, 98 DTC 6530 (FCA)

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Douglas v. The Queen, 90 DTC 6597 (FCTD)

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The Queen v. Merten, 90 DTC 6600 (FCTD)

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The Queen v. Cork, 90 DTC 6358 (FCA)

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The Queen v. Sadavoy, 88 DTC 6065, [1988] 1 CTC 178 (FCTD)

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Plante v. The Queen, 83 DTC 5378, [1983] CTC 341 (FCTD)

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Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) 61

Brooks v. The Queen, 78 DTC 6505, [1978] CTC 761 (FCTD)

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Randall v. Minister of National Revenue, 67 DTC 5151, [1967] CTC 236, [1967] S.C.R. 484

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Cumming v. MNR, 67 DTC 5312, [1967] CTC 462 (Ex Ct)

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See Also

Shenanigans Media Inc. v. The Queen, 2017 TCC 180 (Informal Procedure)

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Landry v. The Queen, 2014 DTC 1198 [at 3768], 2014 TCC 275 (Informal Procedure)

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Lavoie v. The Queen, 2014 DTC 1104 [at 3218], 2014 TCC 68

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Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) cottage used 10 days for personal use and 160 days for business was primarily for business use 55
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) deducting home renovations tenuously related to home office was not grossly negligent 188

Phillips v. The Queen, 2012 DTC 1278 [at 3823], 2012 TCC 337

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Desgagné v. The Queen, 2012 DTC 1237 [at 3664], 2012 TCC 63 (Informal Procedure)

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Bruno v. The Queen, 2012 DTC 1260 [at 3762], 2012 TCC 316 (Informal Procedure)

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Bégin v. The Queen, 2012 DTC 1111 [at 3061], 2012 TCC 18 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business commissions on personal/family policies 89

Chapman v. The Queen, 2004 DTC 3310, 2004 TCC 617 (Informal Procedure)

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Fehrenbach v. MNR, 95 DTC 860 (TCC)

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Sword v. MNR, 90 DTC 1798 (TCC)

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Parikh v. Sleeman, [1990] BTC 142 (C.A.)

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MacKinlay v. Arthur Young McClelland Moores & Co., [1989] BTC 587 (HL)

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Gurney v. Richards, [1989] BTC 326 (Ch.D.)

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Mallalieu v. Drummond, [1983] BTC 380, [1983] 2 All E.R. 1095 (HL)

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 25

White v. MNR, 60 DTC 113 (TAB)

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Administrative Policy

15 November 2012 Internal T.I. 2012-0459321I7 F - Biens locatifs - frais de déplacement

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose deductibility of travel expenses to manage rental properties partly turns on whether single or multiple locations 189

13 February 2012 External T.I. 2011-0426471E5 - Travel Expenses

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28 February 2005 External T.I. 2004-0108551E5 - Disability Insurance Through a Professional Assoc.

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22 September 1998 Memorandum 982320

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23 June 1994 T.I. 940346 (C.T.O. "Seminar Expenses")

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Tax Topics - Income Tax Act - Section 67 55

15 February 1993 T.I. 933421 (C.T.O. "Travel Expenses - Rental Property")

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4 May 1992 TI 920636

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3 April 1992 T.I. 9206128 (May 1993 Access Letter, p. 191, ¶C9-264)

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27 September 1991 T.I. (Tax Window, No. 10, p. 20, ¶1488)

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6 March 1991 Memorandum (Tax Window, No. 1, p. 15, ¶1146)

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Articles

Income Tax Technical News, : Comment on Scott case.

Paragraph 18(1)(l) - Use of recreational facilities and club dues

See Also

Hewlett-Packard (Canada) Co. v. Canada, 2005 DTC 976, 2005 TCC 398

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Words and Phrases
lodge

Administrative Policy

7 January 2013 External T.I. 2012-0460021E5 F - Remboursement de cotisations à un club

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) where “membership in a fitness centre allows the employee to meet … specific conditions [of employment,” the test of “more than 50% … to the employer's advantage” may be met 172

Income Tax Technical News, No. 12 under "Meals and Beverages at Golf Clubs"

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17 November 1993 Memorandum 933016 (C.T.O. "Membership Fees")

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21 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 22)

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7 March 1990 T.I. (August 1990 Access Letter, ¶1367)

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2 March 1990 T.I. (August 1990 Access Letter, ¶1367)

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Subparagraph 18(1)(l)(i)

Cases

The Queen v. Sie-Mac Pipeline Contractors Ltd., 92 DTC 6461 (FCA)

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Words and Phrases
use

The Queen v. C.I.P. Inc., 88 DTC 6005, [1988] 1 CTC 32 (FCTD)

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The Queen v. Jaddco Anderson Ltd., 84 DTC 6135, [1984] CTC 137 (FCA)

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See Also

Fehrenbach v. MNR, 95 DTC 860 (TCC)

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13 May 2016 External T.I. 2016-0635601E5 F - Dépenses de commandite

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1 March 2013 External T.I. 2013-0477911E5 - Expenses to host employees and spouses at a resort

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20 July 1995 External T.I. 5-950474 -

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21 November 1994 T.I. 942439 (C.T.O. "Use of a Lodge")

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2 August 1994 Internal T.I. 4-941841 -

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6 June 1994 T.I. 932878 (C.T.O. "Meaning of Lodge")

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lodge

29 August 1991 T.I. (Tax Window, No. 8, p. 19, ¶1426)

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84 C.R. - Q.15

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Paragraph 18(1)(m) - Limitation re employee stock option expenses

Cases

Mobil Oil Canada Ltd. v. Canada, 2001 DTC 5668, 2001 FCA 333

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Words and Phrases
royalties

Utah Mines Ltd. v. The Queen, 92 DTC 6194 (FCA)

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Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing income determined annually 32

See Also

Cogema Resources Inc. v. The Queen, 2004 DTC 3674, 2005 TCC 750

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Hamilton v. The Queen, 97 DTC 787 (TCC)

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Administrative Policy

29 March 1994 External T.I. 5-933333 -

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28 March 1991 Memorandum (Tax Window, No. 1, p. 21, ¶1141)

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89 C.P.T.J. - Q6

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89 C.P.T.J. - Q7

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Paragraph 18(1)(p) - Limitation re personal services business expenses

Administrative Policy

19 January 1993 T.I. (Tax Window, No. 28, p. 17, ¶2372)

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Paragraph 18(1)(r) - Certain automobile expenses

Administrative Policy

27 April 1990 T.I. (September 1990 Access Letter, ¶1410)

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Paragraph 18(1)(t) - Payments under different acts

Cases

Doulis v. The Queen, 2014 DTC 1054 [at 2933], 2014 TCC 26 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) tax arrears interest is not a business expense 82
Tax Topics - Income Tax Act - Section 9 - Interest Income tax arrears interest is not a business expense 82

Administrative Policy

Example 5

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) 206

Provincial income tax

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Paragraph 18(1)(u) - Fees — individual saving plans

Cases

Wickham Estate v. The Queen, 2015 DTC 10125 [at 102], 2014 TCC 352 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management pro rata denial based on portfolio portion invested in RRIF 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) payments to (otherwise) retired investment manager deductible 263