Section 110.1

Subsection 110.1(1) - Deduction for gifts

Paragraph 110.1(1)(a) - Charitable gifts

Cases

Hudson Bay Mining and Smelting Co., Ltd. v. The Queen, 86 DTC 6244, [1986] 1 CTC 484 (FCTD), aff'd 89 DTC 5515 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 81

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose donations deductible as business expenses rather than as gifts 92

See Also

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 CCI 3

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a) consideration for "gift" was elimination of obligation to invest the funds 503
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose purpose of payment was to extricate from a regional economic-development obligation rather than to enhance business reputation 220

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 CCI 3

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Words and Phrases
gift
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose purpose of payment was to extricate from a regional economic-development obligation rather than to enhance business reputation 220
Tax Topics - Income Tax Act - 101-110 - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a) payment relieving of a correlative contractual obligation was not a gift 120

Emballages Starflex Inc. v. Agence du revenu du Québec, 2016 QCCA 1856

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose gifts to charities likely cannot be deducted as business expenses 207
Tax Topics - Statutory Interpretation - Specific v. General Provisions charitable gift rules a complete code 144

Pustina v. The Queen, 96 DTC 1594 (TCC)

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Administrative Policy

18 November 2003 External T.I. 2003-001469 -

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29 January 1997 T.I. 963494

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6 June 1994 T.I. 933590 (C.T.O. "Corporate Gift of a Life Insurance Policy"

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9 July 1993 T.I. 930660 (C.T.O. "Whether Corporation can make Donation Rather than Estate"; Tax Window, No. 33, p. 6, ¶2641)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 52

IT-110R2 "Deductible Gifts and Official Donation Receipts"

Articles

Alan Steinfeld, Stephen Moverley, "When is a Gift Completed?", All England Legal Opinion, No. 10, July 2001.

Paragraph 110.1(1)(b) - Gifts to Her Majesty

Administrative Policy

ATR-63, 20 April 1995 "Donations to Agents of the Crown"

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20 January 1995 External T.I. 5-950041 -

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16 December 1992 T.I. 923559 (C.T.O. "Crown Gifts to Agents of Her Majesty")

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Paragraph 110.1(1)(d)

Administrative Policy

4 April 2016 Internal T.I. 2016-0625241I7 F - Application of section 207.31

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.31 tax on sales of ecological lands applies even if no deduction was claimed 124

Subsection 110.1(15)

Administrative Policy

31 March 2017 External T.I. 2016-0630351E5 - Return of a gift

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(26) return of gift made 35 years ago 277
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Charitable Foundation gift potentially could be returned by charity pursuant to a condition subsequent 161