Income-Producing Purpose

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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Words and Phrases
income tax

McNeill v. The Queen, 2000 DTC 6211 (FCA)

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65302 British Columbia Ltd. v. Canada, 99 DTC 5799, [1999] 3 S.C.R. 804

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Taylor v. The Queen, 97 DTC 5120 (FCA)

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Amway of Canada. Ltd. v. The Queen, 96 DTC 6135 (FCA)

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Tonn v. The Queen, 96 DTC 6001 (FCA)

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Poetker v. MNR, 95 DTC 5614 (FCA)

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The Queen v. Shefner Estate, 93 DTC 5482 (FCTD)

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Parkland Operations Ltd. v. The Queen, 90 DTC 6676 (FCTD)

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Graves v. The Queen, 90 DTC 6300 (FCTD)

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

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La Compagnie Idéal Body Inc. v. The Queen, 89 DTC 5344 (FCTD)

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Moloney v. The Queen, 89 DTC 5062 (FCTD), aff'd 92 DTC 6570 (FCA)

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Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175

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Mott v. The Queen, 88 DTC 6359, [1988] 2 CTC 127 (FCTD)

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Locations of other summaries Wordcount
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)

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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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Sunshine Mining Co. v. The Queen, 75 DTC 5126 (FCTD)

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The Queen v. Clark, 74 DTC 6242, [1974] CTC 305 (FCTD)

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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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)

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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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Associated Investors of Canada Ltd. v. MNR, 67 DTC 5096 (Ex. Ct.)

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Southam Business Publications Ltd. v. MNR, 66 DTC 5215, [1966] CTC 265 (Ex. Ct.), briefly aff'd 67 DTC 5150 (SCC)

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Premium Iron Ores Ltd. v. Minister of National Revenue, 66 DTC 5280, [1966] CTC 391, [1966] S.C.R. 685

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Quemont Mining Corp. Ltd. v. MNR, 66 DTC 5376, [1966] CTC 570 (Ex. Ct.), aff'd 70 DTC 6046 (SCC)

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Seaboard Advertising Co. Ltd. v. MNR, 65 DTC 5188, [1965] CTC 310 (Ex. Ct.)

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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 77

MNR v. E.H. Pooler & Co. Ltd., 62 DTC 1321 (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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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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Royal Trust Co. v. MNR, 57 DTC 1055, [1957] CTC 32 (Ex. Ct.)

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Montship Lines Ltd. v. MNR, 54 DTC 1151 (Ex. Ct.), briefly aff'd 55 DTC 1060 (SCC)

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Imperial Oil Ltd. v. MNR, 3 DTC 1090, [1947] CTC 353 (Ex. Ct.)

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See Also

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 - 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)

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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, 500-80-019409-110 (Cour du Québec)

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Tax Topics - Treaties - 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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Harvey v. The Queen, 2013 TCC 298

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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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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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Tax Topics - Income Tax Act - Section 67.6 69

Big Bad Voodoo Daddy v. The Queen, 2011 DTC 1173 [at 955], 2011 TCC 226

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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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Bilous v. The Queen, 2011 DTC 1126 [at 710], 2011 TCC 154

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Locations of other summaries Wordcount
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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Mensah v. The Queen, 2008 DTC 4358, 2008 TCC 378

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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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Falkener v. The Queen, 2007 DTC 1470, 2007 TCC 514 (Informal Procedure)

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Ellis v. The Queen, 2007 DTC 996, 2007 TCC 289, aff'd 2008 DTC 6230, 2008 FCA 92

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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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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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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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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)

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Coté v. The Queen, 99 DTC 5215 (FCTD)

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Gagnon v. The Queen, 99 DTC 845 (TCC)

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Splend'or Industries Ltd. v. The Queen, 99 DTC 560 (TCC)

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SPG International Ltée v. The Queen, 98 DTC 1093 (TCC)

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Robitaille v. The Queen, 97 DTC 346 (TCC)

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C.I.R. (Hong Kong) v. Cosmotron Manufacturing Co. Ltd., [1997] B.T.C. 465 (P.C.)

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Vodafone Cellular Ltd. v. Shaw, [1997] BTC 247 (C.A.)

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Port Colbourne Poultry Ltd. v. The Queen, 97 DTC 237 (TCC)

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Sunys Petroleum Inc. v. The Queen, 96 DTC 1759 (TCC)

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Ogden Funeral Homes Ltd. v. The Queen, 94 DTC 1405 (TCC)

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Grunbaum v. The Queen, 94 DTC 1384 (TCC)

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Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)

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RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)

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Harrowston Corporation v. The Queen, 93 DTC 995 (TCC), aff'd 96 DTC 6544 (FCA)

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Ginn v. MNR, 92 DTC 2233 (TCC)

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United Color and Chemicals Ltd. v. MNR, 92 DTC 1259 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 44

ELB Productions Ltd. v. MNR, 91 DTC 1466 (TCC)

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Cassidy's Ltd. v. MNR, 89 DTC 686 (TCC)

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Heather v. P-E Consulting Group Ltd. (1972), 48 T.C. 293 (CA)

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Horton Steel Works Ltd. v. MNR, 72 DTC 1123, [1972] CTC 2147 (T.R.B.)

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Harrods (Buenos Aires) Ltd. v. Taylor-Gooby (1964), 41 T.C. 450 (CA)

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Morgan v. Tate & Lyle Ltd., [1955] A.C. 21 (H.L.)

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Canadian Fruit Distributors Ltd. v. MNR, 54 DTC 1145, [1954] CTC 284 (Ex. Ct.)

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James Snook & Co., Ltd. v. Blasdale (1952), 33 T.C. 244 (CA)

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Newsom v. Robertson (1952), 33 T.C. 452 (CA)

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Fairrie v. Hall (1947), 28 T.C. 200 (K.B.D.)

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Bassett Enterprises, Ltd. v. Petty (1938), 21 T.C. 730 (K.B.D.)

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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.)

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The Herald and Weekly Times Ltd. v. Federal Commissioner of Taxation (1932), 2 A.T.D. 169 (H.C. of A.)

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B.W. Noble, Ltd. v. Mitchell (1927), 11 TC 372 (CA)

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British Insulated and Halsby Cables, Ltd. v. Atherton, [1926] A.C. 205 (HL)

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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 - Improvements v. Repairs or Running Expense pension fund settlement was one-time expenditure for enduring benefit 168

C.I.R. v. Alexander Von Glehn & Co. Ltd. (1920), 12 T.C. 233 (CA)

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Administrative Policy

26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu

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Locations of other summaries Wordcount
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

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

S2-F1-C1 - Health and Welfare Trusts

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Provincial income tax

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24 March 2015 External T.I. 2012-0470991E5 F - Mutual fund trust

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Locations of other summaries Wordcount
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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26 February 2014 External T.I. 2013-0510921E5 F - Remboursement de frais médicaux à un employé

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business exempt disability insurance proceeds 260

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

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AD-00-02 8 February 2000 Communiqué to All Audit Divisions Entitled "Take-Over Bid Costs"

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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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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 15 - Subsection 15(1) 74

2 July 1991 TI (Tax Window, No. 5, p. 21, ¶1327)

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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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86 C.R. - Q.78

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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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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"

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IT-223 (Cancelled) "Overhead Expense Insurance vs. Income Insurance" 26 May 1975

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IT-124R5 "Contributions to Registered Retirement Savings Plans"

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) 0

IC 77-11 "Sales Tax Reassessments - Deductibility in Computing Income"

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Articles

Krishna, "What Constitutes a Business?", Canadian Current Tax, June 1995, Vol. 5, No. 9, p. 90.

Fien, "A Directors' Liability and Indemnifications, Section 160 Assessments, and Ordinary Course of Business Provisions", 1992 Conference Report, pp. 53:21-53:26

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