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 TCC 3, aff'd on s. 18(1)(a) grounds 2019 CAF 36

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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 224
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts payment relieving of a correlative contractual obligation was not a gift 125

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. 2003-0014695 - GRANT OF STOCK OPTIONS TO CHARITY

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29 January 1997 External T.I. 9634945 - DONATIONS TO NPO

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6 June 1994 External T.I. 9335905 - CORPORATE GIFT OF A LIFE INSURANCE POLICY

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9 July 1993 External T.I. 9306605 - WHETHER CORPORATION CAN MAKE DONATION RATHER THAN ESTATE

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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. 9500415 - GIFTS TO CROWN AGENTS

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16 December 1992 923559A - CROWN GIFTS TO AGENT 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 130

Subparagraph 110.1(1)(d)(iii)

Cases

YELLOW POINT LODGE LTD. v. HER MAJESTY THE QUEEN, 2020 FCA 195

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(11) requirement to assess where conditions met 334
Tax Topics - Statutory Interpretation - French and English Version "peut" (may) in French version accorded with a sense of the English version's "shall" 80

See Also

Yellow Point Lodge Ltd. v. The Queen, 2019 TCC 178, aff'd 2020 FCA 195

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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 285
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 169

Subsection 110.1(6)

Administrative Policy

7 October 2019 Internal T.I. 2019-0801871I7 - Loanbacks

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(16) each gift is reduced by the aggregate NAL loans 396