Know-How and Training

Cases

International Nickel Co. of Canada Ltd. v. MNR, 71 DTC 5332 (FCTD)

The taxpayer made continual outlays on scientific research carried out by its personnel in order to identify improvements to its methods for...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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,...

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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...

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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

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