Cases
International Nickel Co. of Canada Ltd. v. MNR, 71 DTC 5332, [1971] CTC 604 (FCTD)
The taxpayer made continual outlays on scientific research carried out by its personnel in order to identify improvements to its methods for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | 90 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Lessening of Competition | 145 | |
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) | s. 37 permits deduction of capital expenditures on research | 114 |
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 145 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 16 | 59 |
See Also
Perron-Ali v. The Queen, 2021 TCC 6 (Informal Procedure)
The taxpayers (who were spouses) were conceded by the Crown to have deductible losses from a rental business in 2012. In 2011 they had not begun...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 | training expenses were eligible capital expenditures | 114 |
Setchell v. The Queen, 2006 DTC 2279, 2006 TCC 37 (Informal Procedure)
Before going on to find that an individual who had been making serious and continuing efforts to establish a business of providing for personal...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Lessening of Competition | 93 |
Shaver v. The Queen, 2003 DTC 2112, 2004 TCC 10
Expenses incurred by the taxpayer, an Amway distributor, in attending "business training seminars" (characterized by the court as conventions) in...
Shaw Flexible Tubes v. MNR, 68 DTC 443 (TAB)
The taxpayer agreed with a U.S. corporation ("Moore") that in consideration for an exclusive licence for the use in Canada by the taxpayer of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Lessening of Competition | 103 |
British Sugar Manufacturers, Ltd. v. Harris (1937), 21 TC 528 (C.A.)
The taxpayer agreed to pay 20% of its net profits to other corporations in consideration for their provision of managerial services and advice on...
Administrative Policy
6 October 2017 APFF Roundtable Q. 12, 2017-0709111C6 F - Dépenses relatives à un congrès
CRA stated:
Where a taxpayer has incurred expenses related to a convention in order to earn income from a business and such expenses are not...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(10) | non-capital convention expenses incurred as business expense may be deducted without refererence to s. 20(10) - but “historically” convention expenses viewed as capital expenditures | 118 |
22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation
As part of the carrying on of its training business, the taxpayer provides breakfast and dinner, as well as a coffee break. Respecting the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) | Pink Elephant followed/potential exception for training business where it breaks out meals on its invoices | 212 |
| Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(1) | trainees required to break out meal portion of their invoices even if not separately identified | 86 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) | deductibility of meal portion of training charges may be denied under s. 18(1)(h) | 114 |
28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation
When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expense incurred in course of operating real property need not have a direct effect on profit | 386 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(10) | convention expenses providing an enduring benefit may be deducted within the s. 20(10) limitations | 185 |
7 April 2006 External T.I. 2005-0152801E5 F - Remboursement de frais de scolarité
In finding that the payment by a corporation of the expenses (tuition, accommodation and travel) for Bob, its sole employee and sole shareholder,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | paying costs for its sole shareholder to get an MBA was not a taxable benefit | 149 |
25 May 2004 External T.I. 2003-0051291E5 F - Formation et croisière
Are expenses incurred by members of an Association respecting conventions, symposia and seminars held during a cruise deductible from their...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(10) | costs of cruise, if not viewed as training, would be non-deductible as they were incurred outside Canada | 194 |
28 June 2001 External T.I. 2000-0060465 F - déductibilité - frais d'internet
Before finding that the cost of subscribing to Internet services, including the cost of renting a modem, incurred to access financial information...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | internet costs incurred for investment research purposes were not deductible under s. 20(1)(bb) | 49 |