Reasonable Expectation of Profit

Cases

The Queen v. Gulf Canada Resources Ltd., 96 DTC 6065, [1996] 2 CTC 55 (FCA)

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Walls v. The Queen, 2000 D.TC 6025 (F.C.A.)

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Kuhlmann v. Canada, 98 DTC 6652 (FCA)

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Mohammad v. The Queen, 97 DTC 5503 (FCA)

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The Queen v. Donnelly, 97 DTC 5499 (FCA)

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Watt Estate v. The Queen, 97 DTC 5459 (FCA)

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Attorney General of Canada v. Mastri, 97 DTC 5420 (FCA)

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Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence failure to report revenue did not evidence its non-receipt 42
Tax Topics - General Concepts - Onus taxpayer demolished Minister's assumptions with uncontradicted testimony 41
Tax Topics - General Concepts - Payment & Receipt unrecorded revenues 148
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) brief earning of rental income 130
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit reasonable expectation of profit test directed only at existence of business source 85
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) integrated farming equipment and auto leasing 95
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) generation of revenue for a short time was sufficient 352
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) deemed property to be acquired for an income-producing purpose 37
Tax Topics - Statutory Interpretation - Drafting Style absence of specific-hold period was telling 85
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius 69
Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 26

Walls v. The Queen, 96 DTC 6142, [1996] 2 CTC 14 (FCTD)

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Tonn v. The Queen, 96 DTC 6001, [1996] 1 CTC 205, [1996] 1 CTC 339 (FCA)

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Yaki v. The Queen, 94 DTC 6637, [1994] 2 CTC 361 (FCTD)

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Landry v. The Queen, 94 DTC 6624 (FCA)

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McGovern v. The Queen, 94 DTC 6527, [1994] 2 CTC 231 (FCTD)

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Engler v. The Queen, 94 DTC 6280, [1994] 2 CTC 64 (FCTD)

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Johnson v. The Queen, 93 DTC 5462 (FCTD)

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DesChênes v. The Queen, 93 DTC 5234, [1993] 2 CTC 107 (FCTD)

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Edwardes v. The Queen, 91 DTC 5635, [1991] 2 CTC 269 (FCTD)

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Blake v. The Queen, 91 DTC 5574 (FCTD)

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Bigelow v. The Queen, 90 DTC 6262, [1990] 1 CTC 351 (FCTD)

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The Queen v. Demers, 90 DTC 6216, [1990] 1 CTC 317 (FCTD)

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McNeill v. The Queen, 89 DTC 5516, [1989] 2 CTC 310 (FCTD)

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Posno v. The Queen, 89 DTC 5423, [1989] 2 CTC 234 (FCTD)

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Madronich v. The Queen, 89 DTC 5093, [1989] 1 CTC 247 (FCTD)

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Coupland v. The Queen, 88 DTC 6251, [1988] 1 CTC 414, 88 DTC 6252 (FCTD)

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Chequer v. The Queen, 88 DTC 6169, [1988] 1 CTC 257 (FCTD)

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The Queen v. Gorjup, 87 DTC 5348, [1987] 2 CTC 129 (FCTD)

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London Life Insurance Co. v. The Queen, 87 DTC 5312, [1987] 2 CTC 90 (FCTD), aff'd 90 DTC 6001 (FCA)

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Magee v. The Queen, 87 DTC 5282, [1987] 2 CTC 17 (FCTD)

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Meech v. The Queen, 87 DTC 5251, [1987] 1 CTC 421 (FCTD)

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Firestone v. The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)

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Croutch v. The Queen, 86 DTC 6453, [1986] 2 CTC 246 (FCTD)

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Gillis v. The Queen, 78 DTC 6103, [1978] CTC 44 (FCTD)

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Moldowan v. The Queen, 77 DTC 5213, [1977] CTC 310, [1978] 1 S.C.R. 480

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McLaws v. The Queen, 76 DTC 6005, [1976] CTC 15 (FCTD)

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See Also

Allen v. The Queen, 99 DTC 968 (TCC)

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Witkin v. The Queen, 98 DTC 1933 (TCC)

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Heier v. The Queen, 97 DTC 739, [1997] 1 CTC 2471 (TCC)

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Griffin v. The Queen, 96 DTC 1731 (TCC)

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Heenan v. The Queen, 96 DTC 1344 (TCC)

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Roopchan v. The Queen, 96 DTC 1338, [1995] 2 CTC 2415 (TCC)

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Mattison v. The Queen, 95 DTC 489 (TCC)

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Administrative Policy

Income Tax Technical News, No. 16

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11 December 1998 Internal T.I. 9828647 - PARAGRAPH 18(1)(A)

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28 May 1990 T.I. (October 1990 Access Letter, ¶1446)

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October 1989 Revenue Canada Round Table - Q. 2 (Jan. 90 Access Letter, ¶1075)

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87 C.R. - Q.35

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84 C.R. - Q.75

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Articles

Joel A. Nitikman, "Reasonable Expectation of Profit - Where Are We Now?", Canadian Current Tax, Vol 8, No. 8, May 1998, p. 81.

John R. Owen, "The Reasonable Expectation of Profit Test: Is There a Better Approach?", 1996 Canadian Tax Journal, Vol. 44, No. 4, p. 979. [cited in the Hickman Motors case, supra, at p. 5373].

Silver, "Great Expectations: Are They Reasonable?", 1995 Corporate Management Tax Conference Report, c. 6.