Incurring of Expense

Cases

Fédération des Caisses Populaires Desjardins de Montréal v. Canada, 2002 DTC 7413, 2001 FCA 27

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Wawang Forest Products Ltd. v. The Queen, 2001 DTC 5212, 2001 FCA 80

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Words and Phrases
contingent liability

Buck Consultants Ltd. v. Canada, 2000 DTC 6015 (FCA)

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Canada v. Robinson, 98 DTC 6232 (FCA)

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Placer Dome Inc. v. The Queen, 91 DTC 5261 (FCTD), rev'd 92 DTC 6402 (FCA)

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The Queen v. Nomad Sand and Gravel Ltd., 91 DTC 5032 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Accounting Principles 85

The Queen v. Ken & Ray's Collins Bay Supermarket Ltd., 75 DTC 5346, [1975] CTC 504 (FCTD)

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Aluminium Co. of Canada Ltd. v. The Queen, 74 DTC 6408, [1974] CTC 471 (FCTD)

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J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC)

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Time Motors Limited v. Minister of National Revenue, 69 DTC 5149, [1969] CTC 190, [1969] S.C.R. 501

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Rossmor Auto Supply Ltd. v. MNR, 62 DTC 1080 (Ex. Ct.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) interest-bearing loans to tire customers 94

See Also

Lewski v Commissioner of Taxation, [2017] FCAFC 145

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Words and Phrases
incur
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) an alternate resolution that the taxpayer was not entitled to an income distribution if Revenue denied a trust deduction made her entitlement contingent and non-includible 356
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) since the taxpayer through her husband as agent had knowledge of an income distribution, her subsequent purported disclaimer was not immediate 296
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) a trust income declaration that was subject to a tax contingency did not result in an income inclusion to the beneficiary 145
Tax Topics - General Concepts - Agency knowledge of agent imputed to principal 206

Edison Transportation, LLC v. The Queen, 2016 TCC 80

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Window Dressing appearance of 3rd party ownership was window dressing 109

Transalta Corporation v. The Queen, 2012 DTC 1106 [at 3044], 2012 TCC 86

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt past services 40
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) no bilateral agreement to pay bonuses only in shares 223

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

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Northwood Pulp and Paper Ltd. v. The Queen, 96 DTC 1105 (TCC), aff'd 98 DTC 6640 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 48

Commissioner of Inland Revenue (New Zealand) v. Mitsubishi Motors Ltd., [1995] B.T.C. 398 (P.C.)

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Mara Properties Ltd. v. The Queen, 93 DTC 1449 (TCC), ultimately aff'd 96 DTC 6309, [1996] 2 S.C.R. 161

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Coles Myer Finance Ltd. v. Federal Commissioner of Taxation, 93 A.T.C. 4214 (H.C.)

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Co-operator's General Insurance Co. v. MNR, 93 DTC 303 (TCC)

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ISBA Construction Inc. v. MNR, 90 DTC 1940 (TCC)

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Lawrence v. MNR, 90 DTC 1491 (TCC)

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Ensign Tankers (Leasing) Ltd. v. Stokes, [1989] B.T.C. 410 (Ch.D.)

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Words and Phrases
incur to incur

Dibro Investments Ltd. v. MNR, 87 DTC 210 (TCC)

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Edmonton Liquid Gas Ltd. v. The Queen, 84 DTC 6526, [1984] CTC 536 (FCA)

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Words and Phrases
incur to incur

Canada Packers Ltd. v. MNR, 68 DTC 682 (TAB)

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Administrative Policy

28 October 2016 External T.I. 2016-0654331E5 F - Transfer of rights to income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Nature of Income where rental lands purchased subject to obligation to pay the rents to vendor, rents did not have quality of income to purchaser under s. 9 159
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) where rental lands purchased subject to obligation to pay the rents to NAL vendor, s. 56(4) trumps s. 9 to include rents in purchaser’s income 157
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) could apply to shareholder of purchaser of lands if vendor did not pay FMV consideration for retaining rights to rents 162

14 February 2012 Internal T.I. 2012-0435241I7 - Prepaid Rent and Escalating Rent Payments

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16 June 2009 Internal T.I. 2009-0312851I7 - Deductibility of Average Rent for Long Term Lease

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27 April 1995 TI 950168 (CTO "Deductibility of Rent Expense")

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11 April 1995 TI 941473 (CTO "Deductibility of 'Net Smelter Return'")

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93 C.P.T.J. - Q.42

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18 November 1992 Memorandum 921979 (December 1993 Access Letter, p. 407, ¶C9-286)

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16 May 1991 TI (Tax Window, No. 3, p. 30, ¶1258)

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28 March 1991 TI (Tax Window, No. 1, p. 9, ¶1175)

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