Cases
Gaynor v. The Queen, 91 DTC 5288, [1991] 1 CTC 470 (FCA)
Pratte J.A. found in light of the principle that Canadian currency "is the only monetary standard of value known to Canadian law", that it was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | different FX spot rates for cost and proceeds | 151 |
Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA)
A crude oil royalty was routinely expressed in money and was, thus, clearly an "amount".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(o) | 88 | |
| Tax Topics - Income Tax Act - Section 169 | 57 | |
| Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 57 |
MNR v. Burns, 58 DTC 1028, [1958] CTC 51 (Ex Ct), briefly aff'd 59 DTC 1328 (SCC)
The taxpayer, when it sold cottages it had constructed, usually accepted second mortgages from the purchasers which it would subsequently sell at...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 102 | |
| Tax Topics - Income Tax Act - Section 76 | 37 | |
| Tax Topics - Income Tax Act - Section 76 - Subsection 76(1) | 133 |
See Also
Gibson v. The Queen, 95 DTC 749, [1996] 1 CTC 2105 (TCC) (Informal Procedure)
The taxpayer transferred his equity in a house to his former spouse in satisfaction of arrears of alimony or maintenance owing to her of $19,946....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | payment in kind if agreement as to the amount | 81 |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 81 |
Tyoxide Canada Inc. v. The Queen, 93 DTC 1499, [1994] 1 CTC 2569 (TCC)
The entitlement of a taxpayer to a Quebec tax credit came within the broad definition of "amount".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | tax credit was "received" | 138 |
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(11.1) - Paragraph 127(11.1)(c) | 36 |
The Queen v. Consumers' Co-Operative Refineries Ltd., 87 DTC 5409, [1987] 2 CTC 204 (FCA)
The references in s. 135(2) to allocations being made at an appropriate "rate" include a nil allocation.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 135 - Subsection 135(2) | 100 | |
| Tax Topics - Statutory Interpretation - Absurdities | 49 |
Administrative Policy
10 October 2003 Roundtable, 2003-0029995 F - Amount of Stock Dividend
With reference to the situation where a corporation governed by the CBCA declares and pays a stock dividend on its common shares by issuing 100...
17 September 2001 External T.I. 2001-0098635 F - Spin-off - T5
CCRA noted that if a spin-off reorganization of a US corporation did not qualify under s. 86.1, it would constitute a dividend-in-kind rather than...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) | general overview re US spin-off | 28 |
90 C.R. - Q49
Where in accordance with the applicable corporate law the declared amount of a stock dividend is a nominal amount of money, that will constitute...
IT-67R3 "Taxable Dividends from Corporations Resident in Canada"
Includes discussion of valuation of dividends in kind.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend Rental Agreement | 48 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | 36 |