Cases
Canadian Imperial Bank of Commerce v. Canada, 2013 DTC 5098 [at 6020], 2013 FCA 122
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Lyncorp International Ltd. v. Canada, 2012 DTC 5032 [at 6684], 2011 FCA 352, aff'g 2010 DTC 1351 [at 4335], 2010 TCC 532
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Teck Corp. v. The Queen, 2005 DTC 5338, 2004 BCCA 514
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McNeill v. The Queen, 2000 DTC 6211 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | 98 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages | deductible damages for breach of non-compete | 102 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss - Damages | 116 |
65302 British Columbia Ltd. v. Canada, 99 DTC 5799, [1999] 3 S.C.R. 804
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 69 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | avoidance of threat to business not relevant to income treatment | 122 |
| Tax Topics - Statutory Interpretation - Drafting Style | avoid policy conjectures in detailed and complex statute | 118 |
| Tax Topics - Statutory Interpretation - Ease of Administration | avoidance of undue burden on taxpayer | 72 |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 117 |
Taylor v. The Queen, 97 DTC 5120 (FCA)
Amway of Canada. Ltd. v. The Queen, 96 DTC 6135 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 148 |
Tonn v. The Queen, 96 DTC 6001 (FCA)
Poetker v. MNR, 95 DTC 5614 (FCA)
Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695
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The Queen v. Shefner Estate, 93 DTC 5482 (FCTD)
Parkland Operations Ltd. v. The Queen, 90 DTC 6676 (FCTD)
Graves v. The Queen, 90 DTC 6300 (FCTD)
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Friedland v. The Queen, 89 DTC 5341 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | payment of legals protected corporate business | 143 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 108 |
La Compagnie Idéal Body Inc. v. The Queen, 89 DTC 5344 (FCTD)
Moloney v. The Queen, 89 DTC 5062 (FCTD), aff'd 92 DTC 6570 (FCA)
Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) - Revising Claims | 73 | |
| Tax Topics - Statutory Interpretation - Comparison of Provisions | "income" has same meaning in different sections | 108 |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 30 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 52 |
Mott v. The Queen, 88 DTC 6359, [1988] 2 CTC 127 (FCTD)
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| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 63 |
The Queen v. Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)
The Queen v. Dorchester Drummond Corp. Ltd., 79 DTC 5163, [1979] CTC 219 (FCTD)
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Deputy Minister of Revenue (Quebec) v. Lipson, [1979] CTC 247, [1979] 1 S.C.R. 833
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Frappier v. The Queen, 76 DTC 6066 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | advances against future losses | 48 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 61 | |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 77 |
Sunshine Mining Co. v. The Queen, 75 DTC 5126 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation | 60 |
The Queen v. Clark, 74 DTC 6242, [1974] CTC 305 (FCTD)
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| Tax Topics - Income Tax Act - Section 245 - Old | 56 |
First Pioneer Petroleums Ltd. v. MNR, 74 DTC 6109, [1974] CTC 108 (FCTD)
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| Tax Topics - Income Tax Act - Section 256 - Subsection 256(2.1) | 54 |
E.R. Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD)
Henry v. Minister of National Revenue, 72 DTC 6005, [1972] CTC 33, [1974] S.C.R. 155
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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 - 101-110 - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a) | donations deductible as business expenses rather than as gifts | 92 |
British Columbia Power Corporation, Limited v. Minister of National Revenue, 67 DTC 5258, [1967] CTC 406, [1968] S.C.R. 17
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 204 |
Associated Investors of Canada Ltd. v. MNR, 67 DTC 5096 (Ex. Ct.)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | 118 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | write-offs deductible on general principles | 161 |
| Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | 119 |
Southam Business Publications Ltd. v. MNR, 66 DTC 5215, [1966] CTC 265 (Ex. Ct.), briefly aff'd 67 DTC 5150 (SCC)
Premium Iron Ores Ltd. v. Minister of National Revenue, 66 DTC 5280, [1966] CTC 391, [1966] S.C.R. 685
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 94 | |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | prior enforceable agreement to on-pay the receipt | 111 |
Quemont Mining Corp. Ltd. v. MNR, 66 DTC 5376, [1966] CTC 570 (Ex. Ct.), aff'd 70 DTC 6046 (SCC)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 71 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 15(2) | 51 |
Seaboard Advertising Co. Ltd. v. MNR, 65 DTC 5188, [1965] CTC 310 (Ex. Ct.)
MNR v. Eldridge, 64 DTC 5338, [1965] 1 Ex. C.R. 758
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | profits of call girl operation were taxable | 77 |
MNR v. E.H. Pooler & Co. Ltd., 62 DTC 1321 (Ex. Ct.)
Meteor Homes Ltd. v. MNR, 61 DTC 1001, [1960] CTC 419 (Ex. Ct.)
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Bannerman v. Minister of National Revenue, 59 DTC 1126, [1959] CTC 214, [1959] S.C.R. 562
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 98 |
British Columbia Electric Railway Company Limited v. The Minister of National Revenue, 58 DTC 1022, [1958] CTC 21, [1958] S.C.R. 133
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation | 96 |
Royal Trust Co. v. MNR, 57 DTC 1055, [1957] CTC 32 (Ex. Ct.)
Montship Lines Ltd. v. MNR, 54 DTC 1151 (Ex. Ct.), briefly aff'd 55 DTC 1060 (SCC)
See Also
Tournier v. The Queen, 2018 TCC 229 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | file storage fees incurred after business cessation were deductible | 234 |
Béliveau v. The Queen, 2018 CCI 87
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | insurance benefits received by an ill dental surgeon to cover her practice expenses were taxable receipts | 268 |
Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 CCI 3, aff'd on s. 18(1)(a) grounds 2019 CAF 36
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| Locations of other summaries | Wordcount | |
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| 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 118.1 - Subsection 118.1(1) - Total Charitable Gifts | 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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| Tax Topics - Income Tax Act - 101-110 - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a) | charitable donations not deductible as business expense | 165 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | charitable gift rules a complete code | 144 |
Acornwood LLP & Ors v. Revenue and Customs Commissioners, [2016] BTC 517, [2016] UKUT 0361 (Tax and Chancery Chamber)
Grenon v. The Queen, 2014 DTC 1207 [at 3805], 2014 TCC 265, aff'd 2016 DTC 5009 [at 6544], 2016 FCA 4
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Emballages Starflex Inc. v. ARC, 2015 QCCQ 7455 (Cour du Québec)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 21 | Quebec provision providing Quebec exemption to amounts exempted by Canada did not apply to Art. XXI, para. 7 of the US Convention | 188 |
Bessette v. ARC (Quebec Revenue Agency), 2014 QCCQ 4329
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| Tax Topics - General Concepts - Sham | professional "services" corporation with no employees | 197 |
Michaud v. The Queen, 2014 DTC 1089 [at 3152], 2014 TCC 83 (Informal Procedure)
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Garber v. The Queen, 2014 DTC 1045 [at 2812], 2014 TCC 1
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | title not held by GP on behalf of partnership | 118 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | no source required if reasonable expectation of income | 225 |
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | fraudulent scheme not a source | 220 |
| Tax Topics - Income Tax Act - Section 96 | GP had fraudulent intention | 235 |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | asset was mere window-dressing | 142 |
Harvey v. The Queen, 2013 TCC 298
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Evidence | 180 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | guilty plea is prima facie proof of income from tax evasion | 101 |
Lequier v. The Queen, 2013 DTC 1012 [at 68], 2012 TCC 380
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) | 101 |
Motech Molding Inc. v. The Queen, 2012 DTC 1293 [at 3913], 2012 TCC 351
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Chow v. The Queen, 2011 DTC 1196 [at 1088], 2011 TCC 263
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 67.6 | 69 |
Big Bad Voodoo Daddy v. The Queen, 2011 DTC 1173 [at 955], 2011 TCC 226 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 96 | 136 |
4145356 Canada Limited v. The Queen, 2011 DTC 1171 [at 937], 2011 TCC 220
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(2) | 342 | |
| Tax Topics - Statutory Interpretation - Consistency | 342 |
Bilous v. The Queen, 2011 DTC 1126 [at 710], 2011 TCC 154
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| Tax Topics - Income Tax Act - Section 67 | 128 |
Bourget v. The Queen, 2011 DTC 1032 [at 143], 2010 TCC 642 (Informal Procedure)
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Doiron v. The Queen, 2010 DTC 1348 [at 4325], 2010 TCC 519, aff'd 2012 DTC 5105 [at 7092], 2012 FCA 126
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Labow v. The Queen, 2010 TCC 408, 2010 DTC 1282 [at 3956], aff'd 2012 DTC 5001 [at 6501], 2011 FCA 305
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | taxpayers appreciated the spurious factual underpinnings | 107 |
Les Entreprises Réjean Goyette inc. v. The Queen, 2009 DTC 1880, 2009 TCC 351
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Jolly Farmer Products Inc. v. The Queen, 2008 DTC 4396, 2008 TCC 409
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|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | 113 |
Mensah v. The Queen, 2008 DTC 4358, 2008 TCC 378
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | no copy of return - no evidence | 54 |
Anjaria v. The Queen, 2008 DTC 2306, 2007 TCC 746 (Informal Procedure)
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ZR v. The Queen, 2007 DTC 1577, 2007 TCC 598
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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 - Damages | focus on origin of claim | 145 |
Falkener v. The Queen, 2007 DTC 1470, 2007 TCC 514 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 31 - Subsection 31(1) | 74 |
Ellis v. The Queen, 2007 DTC 996, 2007 TCC 289, aff'd 2008 DTC 6230, 2008 FCA 92
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 66 |
Renaud c. La Reine, 2006 DTC 3104, 2006 TCC 354
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Wedge v. The Queen, 2005 DTC 1213, 2005 TCC 480
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | 40 |
Welton v. The Queen, 2005 DTC 869, 2005 TCC 359
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O'Flynn v. The Queen, 2005 DTC 556, 2005 TCC 230 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 61 |
Shaver v. The Queen, 2003 DTC 2112, 2004 TCC 10
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Bains v. The Queen, 2003 DTC 376, 2003 TCC 211
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Costigane v. The Queen, 2003 DTC 254, 2003 TCC 67
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| Tax Topics - Income Tax Act - Section 67 | 68 |
Foresbec Inc. v. The Queen, 2002 DTC 1786 (TCC), aff'd 2003 DTC 5455, 2002 FCA 186
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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 15 - Subsection 15(1) | 93 |
International Colin Energy Corp. v. The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)
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Chamberlain v. The Queen, 2002 DTC 2050, 2003 TCC 307 (Informal Procedure)
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Fredette v. The Queen, 2001 DTC 621 (TCC)
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|---|---|---|
| Tax Topics - General Concepts - Ownership | 95 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | s. 245(4) did not apply to abuse of a Regulation - and not abusive to borrow at partner/shareholder level | 392 |
Matt Harris & Son Ltd. v. The Queen, 2001 DTC 28 (TCC) (Informal Procedure)
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Quantetics Corporation v. The Queen, 2000 DTC 2177 (TCC)
Coté v. The Queen, 99 DTC 5215 (FCTD)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 69 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | incurred when grants terminated | 69 |
Gagnon v. The Queen, 99 DTC 845 (TCC)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 36 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | software receipt amortized | 37 |
| Tax Topics - Income Tax Act - Section 67 | 64 |
Splend'or Industries Ltd. v. The Queen, 99 DTC 560 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | 30 |
SPG International Ltée v. The Queen, 98 DTC 1093 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | 86 |
Robitaille v. The Queen, 97 DTC 346 (TCC)
C.I.R. (Hong Kong) v. Cosmotron Manufacturing Co. Ltd., [1997] B.T.C. 465 (P.C.)
Vodafone Cellular Ltd. v. Shaw, [1997] BTC 247 (C.A.)
Port Colbourne Poultry Ltd. v. The Queen, 97 DTC 237 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 61 |
Sunys Petroleum Inc. v. The Queen, 96 DTC 1759 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 149 |
Ogden Funeral Homes Ltd. v. The Queen, 94 DTC 1405 (TCC)
Grunbaum v. The Queen, 94 DTC 1384 (TCC)
Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | 232 | |
| Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1) | main purpose was to make a profit, not take deduction | 254 |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) | no "lease" where failure to provide exclusive possession | 73 |
RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures | 172 |
Harrowston Corporation v. The Queen, 93 DTC 995 (TCC), aff'd 96 DTC 6544 (FCA)
Ginn v. MNR, 92 DTC 2233 (TCC)
United Color and Chemicals Ltd. v. MNR, 92 DTC 1259 (TCC)
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| Tax Topics - General Concepts - Evidence | 44 |
ELB Productions Ltd. v. MNR, 91 DTC 1466 (TCC)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 102 |
Cassidy's Ltd. v. MNR, 89 DTC 686 (TCC)
Heather v. P-E Consulting Group Ltd. (1972), 48 T.C. 293 (CA)
Horton Steel Works Ltd. v. MNR, 72 DTC 1123, [1972] CTC 2147 (T.R.B.)
Harrods (Buenos Aires) Ltd. v. Taylor-Gooby (1964), 41 T.C. 450 (CA)
Morgan v. Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 139 |
Canadian Fruit Distributors Ltd. v. MNR, 54 DTC 1145, [1954] CTC 284 (Ex. Ct.)
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) | 33 | |
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | income reduced to nil by obligation to pay | 149 |
James Snook & Co., Ltd. v. Blasdale (1952), 33 T.C. 244 (CA)
Newsom v. Robertson (1952), 33 T.C. 452 (CA)
Fairrie v. Hall (1947), 28 T.C. 200 (K.B.D.)
Bassett Enterprises, Ltd. v. Petty (1938), 21 T.C. 730 (K.B.D.)
British Sugar Manufacturers, Ltd. v. Harris (1937), 21 TC 528 (C.A.)
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Tata Hydro-Electric Agencies, Bombay v. Income Tax Commissioner, [1937] A.C. 685 (P.C.)
The Herald and Weekly Times Ltd. v. Federal Commissioner of Taxation (1932), 2 A.T.D. 169 (H.C. of A.)
B.W. Noble, Ltd. v. Mitchell (1927), 11 TC 372 (CA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation | 135 |
British Insulated and Halsby Cables, Ltd. v. Atherton, [1926] A.C. 205 (HL)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | pension fund settlement was one-time expenditure for enduring benefit | 168 |
Administrative Policy
27 June 2018 External T.I. 2018-0742881E5 F - Royalties under Canada Petroleum Resources Act
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26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu
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| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | individual’s sideline activity not a business so that revenues exempt | 96 |
4 March 2015 External T.I. 2014-0562151E5 F - Frais de psychothérapie dépense d'entreprise
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | potential choice between claiming therapy expense and credit | 109 |
9 October 2015 APFF Roundtable Q. 10, 2015-0595671C6 F - Question 10 - Table Ronde APFF 2015
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| Tax Topics - General Concepts - Effective Date | price adjustment clause not required to reduce income for an excessive management fee | 99 |
27 June 2014 External T.I. 2013-0500701E5 F - Déductibilité de certaines dépenses
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30 October 2013 External T.I. 2013-0500831E5 F - Frais de bureau à domicile
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(13) | inapplicable where corporation uses its individual shareholder's office | 69 |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) | incidental rental use of home does not result in part disposition | 131 |
2015 Ruling 2013-0513411R3 F - Société de professionnels
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | fees paid by professional practice to family management company | 113 |
20 November 2012 External T.I. 2012-0466891E5 F - Non-Cash Gifts and Non-Cash Awards
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | $500 tax-free non-cash gift amount calculated including sales tax | 48 |
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)(h) | notwithstanding the s. 18(1)(h) postamable limitation to business income, there is a circumscribed deduction for travel to and from single rental property | 188 |
18 September 2012 External T.I. 2012-0442581E5 F - Fiducie au profit d'un athlète amateur
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| Tax Topics - Income Tax Act - Section 143.1 - Subsection 143.1(2) | amounts distributed from athlete trust were business income | 117 |
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | tests for source of business income for amateur athlete | 141 |
S2-F1-C1 - Health and Welfare Trusts
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S4-F2-C1 - Deductibility of Fines and Penalties
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Provincial income tax
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(t) | 170 |
27 May 2014 Internal T.I. 2014-0521631I7 F - Déductibilité d'un alcoomètre
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | full personal element if the expense would have otherwise been paid by the employee | 92 |
24 March 2015 External T.I. 2012-0470991E5 F - Mutual fund trust
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) | flow-through to unitholder of capital gain designated by MFT | 175 |
| Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) | day trading included in investment undertaking | 56 |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(5) - Paragraph 39(5)(a) | election can be made by leveraged day-trading MFT | 175 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | capital v. income character determined at trust level | 88 |
S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | timing of deduction for loss from theft or embezzlement | 126 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | bad debt from fraudulent investment scheme | 77 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 266 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 150 | |
| Tax Topics - Income Tax Act - Section 3 | non-enumerated sources included/hobby receipts, windfalls and true gifts excluded | 908 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(f) | 284 | |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 193 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | voluntary payments | 67 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(c) | 134 |
26 February 2014 External T.I. 2013-0510921E5 F - Remboursement de frais médicaux à un employé
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8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité
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| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | proceeds received as a result of business credit card insurance were not income | 312 |
5 June 2012 External T.I. 2012-0437831E5 - Professional Fees
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| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(o) | voluntary disclosure costs not covered | 39 |
5 October 2012 Roundtable, 2012-0451251C6 F - Excess of foreign tax withheld at source
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | foreign withholdings on American depositary receipts in excess of Treaty-limited rate does not qualify as an income tax | 96 |
21 March 2011 External T.I. 2011-0395011E5 - Deductibility of Ontario SAT
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | 169 |
17 February 2005 External T.I. 2004-010473 -
8 May 2001 Internal T.I. 2001-007985 -
20 November 2003 Internal T.I. 2003-003623 -
16 January 2003 External T.I. 2002-017780 -
AD-00-02 8 February 2000 Communiqué to All Audit Divisions Entitled "Take-Over Bid Costs"
6 February 2002 External T.I. 2001-010560 -
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1 March 2001 External T.I. 2000-006230 -
8 November 1999 T.I. 991413
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax | 16 |
26 January 1999 TI 983160
10 June 1998 Memorandum 980870
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | 32 |
11 March 1997 Internal T.I. 7-970101 -
22 October 1996 TI 962935 (CTO "Deductibility of Employee Relocation Expenses")
28 July 1995 Internal T.I. 7-951496 -
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| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(f) | 26 | |
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 26 |
10 July 1995 T.I. 943044 (C.T.O. Pennsylvania Franchise Tax")
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax | 90 |
10 May 1995 TI (C.T.O "Legal Fees")
1 September 1994 Memorandum 941384 (CTO "Deductibility of Expenses")
4 July 1994 External T.I. 5-941332 -
15 February 1994 T.I. 933046 (C.T.O. "Mortgage Interest Subsidies")
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| Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(2) | 70 |
93 C.M.TC- Q. 5
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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax | 41 |
93 C.P.T.J. - Q.40
28 June 1993 TI (Tax Window, No. 32, p. 10, ¶2604)
10 June 1993 T.I. (Tax Window, No. 31, p. 24, ¶2550)
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 32 |
4 February 1993 T.I. (Tax Window, No. 29, p. 20, ¶2435)
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| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 26 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 26 |
26 January 1993 TI 923284 (November 1993 Access Letter, p. 512, ¶245-051; Tax Window, No. 28, p. 1, ¶2383), 923284)
December 1992 B.C. Tax Executives Institute Round Table, Q. 7 (October 1993 Access Letter, p. 479)
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| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) | 47 | |
| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4) | 25 |
15 December 1992 T.I. (Tax Window, No. 27, p. 18, ¶2334)
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 72 |
22 April 1992 External T.I. 5-921033 -
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| Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) | 26 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | 72 |
2 April 1992 External T.I. 5-920818 -
2 April 1992 TI (Tax Window, No. 18, p. 23, ¶1869)
13 March 1992 External T.I. 5-920029 -
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| Tax Topics - Income Tax Act - Section 135 - Subsection 135(1) | 36 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 53 |
13 March 1992 External T.I. 5-920029 -
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| Tax Topics - Income Tax Act - Section 135 - Subsection 135(1) | 36 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 41 |
6 February 1992 TI 920224 (CTO "XXX and Excise Penalties"; (Tax Window, No. 16, p. 5, ¶1735))
20 January 1992 TI (Tax Window, No. 15, p. 22, ¶1706)
31 January 1992 Memorandum (Tax Window, No. 15, p. 16, ¶1678)
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| Tax Topics - Income Tax Regulations - Regulation 3900 - Subsection 3900(1) | 14 |
24 February 1992 Memorandum (Tax Window, No. 13, p. 11, ¶1615)
19 July 1991 T.I. (Tax Window, No. 7, p. 8, ¶1363)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 74 |
2 July 1991 TI (Tax Window, No. 5, p. 21, ¶1327)
May 1991 T.I. (C.T.O. Fax Service Document No. 96)
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| Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) | 42 |
22 March 1991 T.I. (Tax Window, No. 1, p. 7, ¶1164)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(16) | 60 |
11 May 1990 Memorandum (October 1990 Access Letter, ¶1494)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 10 | |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | 21 |
17 April 1990 TI (September 1990 Access Letter, ¶1436)
29 January 1990 Memorandum (June 1990 Access Letter, ¶1286)
14 December 89 TI (May 1990 Access Letter, ¶1203)
86 C.R. - Q.78
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 13 |
84 CR - Q.72
81 CR - Q.40
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 33 |
81 CR - Q.43
81 C.R. - Q.44
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 31 |
79 CR - Q.20
IT-104R2 "Deductibility of Fines or Penalties"
IT-185R "Losses from Theft, Defalcation or Embezzlement"
IT-467R "Damages, Settlements and Similar Payments"
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Public Policy | 29 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 11 |
IT-488R "Winding-up of 90%-Owned Taxable Canadian Corporations"
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| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) | 0 |
IT-487 "General Limitation on Deduction of Outlays or Expenses"
IT-223 (Cancelled) "Overhead Expense Insurance vs. Income Insurance" 26 May 1975
IT-124R5 "Contributions to Registered Retirement Savings Plans"
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| Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) | 0 |
Articles
Krishna, "What Constitutes a Business?", Canadian Current Tax, June 1995, Vol. 5, No. 9, p. 90.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 0 |