Subsection 15(1) - Benefit conferred on shareholder

Cases

Babich v. Canada, 2013 DTC 5010 [at 5556], 2012 FCA 276, aff'g 2010 TCC 352

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The Queen v. Robinson, 2000 DTC 6176 (FCTD)

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Canada v. Chopp, 98 DTC 6014 (FCA)

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The Queen v. Fingold, 97 DTC 5449 (FCA)

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Hrga v. The Queen, 97 DTC 5165 (FCTD)

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Toma v. The Queen, 95 DTC 5356 (FCTD)

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Penny v. The Queen, 95 DTC 5083 (FCTD)

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Cartwright v. The Queen, 94 DTC 6677 (FCTD)

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Winter v. The Queen, 90 DTC 6681 (FCA)

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Youngman v. The Queen, 90 DTC 6322 (FCA)

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Tax Topics - General Concepts - Onus 83

Vine Estate v. The Queen, 89 DTC 5528 (FCTD)

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Friedland v. The Queen, 89 DTC 5341 (FCTD)

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Grohne v. The Queen, 89 DTC 5220 (FCTD)

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Cooper v. The Queen, 88 DTC 6525, [1989] 1 CTC 66 (FCTD)

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Tax Topics - General Concepts - Illegality income tax consequences attaching to illegal loan 75
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) interest-free loan recognized as obligation rather than benefit 101

R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.)

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Hall v. The Queen, 86 DTC 6208, [1986] 1 CTC 399 (FCTD)

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Indalex Ltd. v. The Queen, 86 DTC 6039, [1986] 1 CTC 219 (FCTD), aff'd 88 DTC 6053, [1988] 1 CTC 60 (FCA)

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Words and Phrases
shareholder

Murphy v. The Queen, 85 DTC 5462, [1985] 2 CTC 248 (FCTD)

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The Queen v. Houle, 83 DTC 5430, [1983] CTC 406 (FCTD)

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Tax Topics - General Concepts - Tax Avoidance 28

Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)

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The Queen v. Schubert, 80 DTC 6366, [1980] CTC 497 (FCTD)

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Tax Topics - General Concepts - Fair Market Value - Other 34

Berbynuk v. The Queen, 78 DTC 6322, [1978] CTC 448 (FCTD)

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Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)

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The Queen v. Ginter, 77 DTC 5274, [1977] CTC 418 (FCA)

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Steeves v. The Queen, 76 DTC 6269, [1976] CTC 470 (FCTD)

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The Queen v. Phillips, 76 DTC 6093, [1976] CTC 126 (FCA)

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Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)

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The Queen v. Neudorf, 75 DTC 5213, [1975] CTC 192 (FCTD)

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The Queen v. Leslie, 75 DTC 5086, [1975] CTC 155 (FCTD)

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 95

Huron Steel Fabricators (London) Ltd. v. M.N.R., 75 DTC 5006, [1974] CTC 889 (FCTD)

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Tax Topics - General Concepts - Fair Market Value - Shares 32

Angle v. M.N.R., 74 DTC 6278, [1975] 2 S.C.R. 248

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Tax Topics - General Concepts - Res Judicata 158

Byke Estate v. The Queen, 74 DTC 6585, [1974] CTC 763 (FCTD)

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Bernstein v. MNR, 74 DTC 6041, [1974] CTC 4 (FCTD), aff'd 77 DTC 5187, [1977] CTC 328 (FCA)

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Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)

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MNR v. Bisson, 72 DTC 6374 (FCTD)

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Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

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MNR v. Pillsbury Holdings Ltd., 64 DTC 5184 (Ex Ct)

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Words and Phrases
confer

See Also

Laliberté v. The Queen, 2018 TCC 186

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) taxable benefit from one company initially bearing costs of shareholder space trip and then being reimbursed by an Opco 208

Melançon v. The Queen, 2018 CCI 73

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Tax Topics - General Concepts - Effective Date rebooking of “expense” as shareholder advance was retroactive tax planning 164

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 160
Tax Topics - General Concepts - Evidence contract must be evinced by documents or conduct

Engelberg v. Agence du revenu du Québec, 2017 QCCQ 14819

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R. v. Golini, 2016 TCC 174

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Tax Topics - General Concepts - Sham sham doctrine did not apply to a "minor pretence" 326
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest deduction on limited recourse loan 293
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of corporate asset to create PUC was abuse of s. 84(1) 244
Tax Topics - Income Tax Act - Section 84 - Subsection 84(1) policy of 84(1) 215

Latham v. The Queen, 2015 DTC 1104 [at 617], 2015 TCC 75

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) deemed dividend not possible where foreclosure eliminated corporations's assets

Charania v. The Queen, 2015 DTC 1103 [at 614], 2015 TCC 80 (Informal Procedure)

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Tax Topics - General Concepts - Effective Date consideration for transfer to shareholder adjusted without price adjustment clause 227

Rogers Estate v. The Queen, 2015 DTC 1029 [at 124], 2014 TCC 348

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) capital gain can arise from property which is not capital property 249
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) exercise of stock option surrender plan for FMV was not "remuneration" 111
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(a) s. 7 a complete code for taxation of stock option benefits 214
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options holding one's employee stock options until just before they expire is not typical of an adventure in the nature of trade 171

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business taxable share interest on loan held by affiliate 158

Tyskerud v. The Queen, 2012 DTC 1179 [at 3453], 2012 TCC 196 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) obvious and substantial shareholder benefit 56

McIntosh v. The Queen, 2012 DTC 1049 [at 2741], 2011 TCC 579 (Informal Procedure)

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Canadian Winesecrets Inc. v. The Queen, 2011 DTC 1310 [at 1742], 2011 TCC 390 (Informal Procedure)

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Tax Topics - General Concepts - Fair Market Value - Other 160

Boulet v. The Queen, 2010 DTC 1015 [at 2602], 2009 TCC 261

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Tax Topics - General Concepts - Fair Market Value - Land binding NAL agreement suppressed land's FMV 207
Tax Topics - Income Tax Act - Section 54 - Principal Residence 61

Potvin v. The Queen, 2008 DTC 4813, 2008 TCC 319 (Informal Procedure)

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Gestion Léon Gagnon Inc. c. La Reine, 2007 DTC 267, 2006 TCC 682

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Park Haven Designs Inc. v. The Quenn, 2006 TCC 685

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Truckbase Corporation v. The Queen, 2006 DTC 2930, 2006 TCC 215 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees shareholder agreement expenses deductible 99

Colubriale c. La Reine, 2006 DTC 2577, 2004 TCC 578

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Tax Topics - General Concepts - Fair Market Value - Land 121

Roth v. The Queen, 2005 DTC 1570, 2005 TCC 484, aff'd 2007 DTC 5222, 2007 FCA 38

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World Corp. v. The Queen, 2003 DTC 951, 2003 TCC 494

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Dobbin v. The Queen, 2003 DTC 118 (TCC)

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Foresbec Inc. v. The Queen, 2002 DTC 1786 (TCC), aff'd 2003 DTC 5455, 2002 FCA 186

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Tax Topics - General Concepts - Sham documents did not reflect legal reality 56
Tax Topics - General Concepts - Tax Avoidance documents did not reflect legal reality 56
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose 79

Robson v. The Queen, 2001 DTC 1039 (TCC)

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Davisson v. The Queen, 2000 DTC 2140 (TCC)

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Safety Boss Ltd. v. The Queen, 2000 DTC 1767 (TCC)

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Pellizzari v. MNR, 87 DTC 56 (TCC)

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Long v. The Queen, 98 DTC 1420 (TCC)

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Donovan v. The Queen, 94 DTC 1143 (TCC), aff'd 96 DTC 6085 (FCA)

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Dale v. The Queen, 94 DTC 1100 (TCC), aff'd supra.

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) shares must be issued within a reasonable time 220
Tax Topics - Statutory Interpretation - Drafting Style 85

Del Grande v. The Queen, 93 DTC 133 (TCC)

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Words and Phrases
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Simpson v. MNR, 92 DTC 1912 (TCC)

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Mullen v. MNR, 90 DTC 1551 (TCC)

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Doyon v. MNR, 90 DTC 1132 (TCC)

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Gendron v. MNR, 89 DTC 582 (TCC)

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President of India v. La Pintada Companid Navigacion S.A., [1985] A.C. 104

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Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend distributions out of share premium based on number of shares held were dividends 211
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) distributions out of share premium based on number of shares held were dividends 211

Administrative Policy

AD-18-01: 2018-03-07 Taxable Benefit for the Personal Use of an Aircraft

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) 656
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) non-deductibility where personal use of corporate aircraft by shareholders 120

May 2016 Alberta CPA Roundtable, Q.15

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Tax Topics - Income Tax Act - Section 67 deduction by corporation of rents/reimbursements paid for use of office in shareholder’s home 192

7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2016-0651771C6 F - Critical Illness Insurance

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14 March 2016 External T.I. 2016-0626781E5 - Neuman Type Situation

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) likely non-applicable where spouse subscribes nominal consideration for Opco shares and receives a large discretionary dividend 242
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) Kieboom treated as entailing disposition of right to receive dividends 316
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) spousal rollover for Kieboom disposition of economic interest 68

9 October 2015 APFF Roundtable Q. 4, 2015-0595541C6 F - Computation of taxable benefit

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7 October 2016 APFF Roundtable, Q.8

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) policy on employees’ purchases of discounted merchandise excludes condos 155

9 October 2015 APFF Roundtable Q. 13, 2015-0595781C6 F - Reimbursement of attributed income

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Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) no secondary adjustments are required for the operation of most income attribution provisions 115

S2-F1-C1 - Health and Welfare Trusts

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29 April 2015 External T.I. 2014-0532691E5 F - Vente – immeuble - syndicat copropriétaire

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation 117
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) a syndicate of condominium co-owners could qualify as a s. 149(1)(l) corporation, so that a capital gain realized by it on a condo sale would be exempt 147

3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(c) apportionment of aircraft use between business and personal 66
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 158
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 781

24 September 2014 External T.I. 2014-0522261E5 - Shareholder benefit on leasehold improvements

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7 August 2014 External T.I. 2014-0528841E5 F - Changement à une résidence principale

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) addition of a door to an exterior wall could be considered a structural change triggering a change of use 128
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(5) Reg. 1102(5) not applicable where door added by tenant to basement rental property 173

16 April 2012 External T.I. 2011-0411491E5 - Taxation of distributions of a US LLC

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) taxable benefit where US taxes on LLC income allocated to indirect Cdn member are paid by LLC or intermediate ULC 155

11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder 164
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder 169
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 218
Tax Topics - Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 216
Tax Topics - General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV 128
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 157

4 December 2013 External T.I. 2012-0465891E5 F - Primes d'assurance / Premiums

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans 164

7 November 2013 External T.I. 2013-0473771E5 - Shareholder of a Not-for-profit corporation

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder NPO member receiving "shareholder" benefit 49

2012 Ruling 2010-0391281R3 - Incentive Plan - Reimbursement Agreement

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1 May 2013 Internal T.I. 2009-0321721I7 - Stock Option Recharge on Grant Date

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Tax Topics - General Concepts - Fair Market Value - Options use of Black-Scholes 136

29 April 2013 External T.I. 2010-0356401E5 - Stock Option Recharge on Grant Date

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5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F - Discretionary Dividend Shares

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7 May 2012 2010 CALU Roundtable, 2012-043566 -

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11 February 2011 External T.I. 2010-0360001E5 - Shareholder benefit - single purpose corporation

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6 December 2011 TEI Roundtable Q. 5, 2011-0427001C6 - 2011 TEI Q#5 - Distributions from Foreign Corp.

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) 2-step approach 142

23 June 2011 External T.I. 2011-0397881E5 - 149(1)(l) Entity - Use of Land by Shareholders

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Memorandum TPM-03 "Downward Transfer Pricing Adjustments Under Subsection 247(2)," 20 October 2003

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2003 Ruling 2002-017470

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Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) share subscription at under-value 61

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 14

1999 Ruling 990259

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 15

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1999 Ruling 983014

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Tax Topics - Income Tax Act - Section 43.1 54

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13 February 1995 T.I. 950323

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94 C.P.T.J. - Q. 26

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20 June 1994 T.I. 940553 (C.T.O. "Dividend Reinvestment and Stock Option Plans")

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16 May 1994 T.I. 940456 (C.T.O. "Court Ordered Corporate Distribution")

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27 March 1994 T.I. 933322 (C.T.O. "Shareholder Benefit")

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(2.1) 83

25 March 1994 T.I. 933550 (C.T.O. "Interest Reduced 15(1) Benefit")

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 80

8 March 1994 Internal T.I. 73-933092 -

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93 C.P.T.J. - Q. 37

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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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7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)

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13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)

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92 C.R. - Q.51

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92 C.R. - Q.32

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) 55

October 1992 Central Region Rulings Directorate Tax Seminar, Q. G (May 1993 Access Letter, p. 230)

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(2) 22

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Tax Topics - Treaties - Income Tax Conventions - Article 10 65

6 April 1992 T.I. (Tax Window, No. 18, p. 3, ¶1851)

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(3) 61

1992 Prairie Provinces Tax Conference, Revenue Canada Round Table, Q. 16 (October 1992 Access Letter, p. 41)

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91 C.R. - Q24

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91 C.R. - Q.16

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(3) 46

30 November 1991 Round Table (4M0462), Q. 3.2 - Inter-Company Loan (C.T.O. September 1994)

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8 November 1991 T.I. (Tax Window, No. 12, p. 8, ¶1561)

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September 1991 Memorandum (Tax Window, No. 10, p. 22, ¶1482)

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28 March 1991 T.I. (Tax Window, No. 1, p. 8, ¶1177)

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15 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 18, ¶1028)

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90 C.R. - Q8

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14 June 1990 T.I. (November 1990 Access Letter, ¶1507)

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27 March 1990 TI (August 1990 Access Letter, ¶1364)

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Tax Topics - General Concepts - Effective Date 34

27 March 1990 T.I. (August 1990 Access Letter, ¶1365)

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89 C.R. - Q.24

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89 C.R. - Q9

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86 C.R. - Q.62

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16 July 1985 Memo 7-4095

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85 C.R. - Q.14

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81 C.R. - Q.49

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Tax Topics - General Concepts - Fair Market Value - Other 45

81 C.R. - Q.51

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80 C.R. - Q.20

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IT-96R5 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures" under "Shareholder Benefit"

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Tax Topics - General Concepts - Fair Market Value - Shares 60

Articles

Perry Truster, "Taxable Benefits: How Much is Taxable?", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2

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Patrick W. Marley, Kim Brown, "Foreign Mergers and 'Demergers' Under Recent Canadian Proposals", Tax Management International Journal, 10 February 2012, Vol 41, No. 2, p. 86

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Gordon Funt, Joel A. Nitikman, "FAPI and Debt Forgiveness - Now You See It, Now You Don't", CCH Tax Topics, No. 1724, 24 March 2005.

David Louis, Michael Goldberg, "Life Insurance: Exploring the Corporate Edge - Part II", Tax Topics No. 1682, June 3, 2004, p. 1.

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(7) 0

Ramaseder, "Substantial Tax Cost May be Associated with Recreational Properties", Taxation of Executive Compensation and Retirement, November 1991, p. 515.

Crawford, "The Personal Use by a Shareholder of Company-Owned Assets and the Youngman Case", 1990 Conference Report, p. 4:35

Durnford, "Benefits and Advantages Conferred on Shareholders", Canadian Tax Journal, May-June 1984, p. 445.

David A. Ward, "Insurance Funding of Buy-Sell Agreements", 1974 Canadian Tax Journal, p. 484

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Paragraph 15(1)(b)

Cases

The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)

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Administrative Policy

2013 Ruling 2012-0463611R3 - Foreign Divisive Reorganization

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23 May 2013 IFA Round Table, Q. 2

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) 197

Articles

Durnford, Toope, "Spousal Support in Family Law and Alimony in the Law of Taxation", Canadian Tax Journal, 1994, Vol. 42, No. 1, p. 1.