Section 56

Table of Contents

Subsection 56(1) - Amounts to be included in income for year

Paragraph 56(1)(a) - Pension benefits, unemployment insurance benefits, etc.

Cases

Woods v. The Queen, 2010 DTC 1095 [at 2996], 2010 TCC 106, aff'd 2011 DTC 5049 [at 5681], 2011 FCA 90

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Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure)

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Words and Phrases
insurance

Subparagraph 56(1)(a)(i)

Cases

Burchill v. Canada, 2010 DTC 5096 [at 6922], 2010 FCA 145

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Context 93

See Also

Gill v. The Queen, 2012 DTC 1261 [at 3764], 2012 TCC 302

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Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions "including without limitation" is expansive 159

Brilla v. The Queen, 98 DTC 1502 (TCC)

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Walker v. The Queen, 95 DTC 753 (TCC)

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Kaiser v. The Queen, 95 DTC 13 (TCC)

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Administrative Policy

10 April 2014 External T.I. 2013-0515681E5 - Death of RPP Member-56(1)(a)

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19 March 2014 External T.I. 2014-0522671E5 - HK Pension and Tax Treaty

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25 June 2012 External T.I. 2011-0398691E5 - Conversion of U.S. Traditional IRA into Roth IRA

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19 June 2012 External T.I. 2011-0407461E5 - Tax on 401(k) Transfer to IRA and IRA Withdrawal

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3 March 2004 External T.I. 2003-004715 -

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16 January 1996 T.I. 952921 (Tax Window Files "401(k), Double Tax in Canada")

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27 October 1994 T.I. 942712 (C.T.O. "Deferral of Lump Sum Severance Payment")

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20 November 1991 T.I. (Tax Window, No. 13, p. 9, ¶1601)

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7 March 1991 T.I. (Tax Window, No. 1, p. 21, ¶1151)

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8 September 89 T.I. (February 1990 Access Letter, ¶1097)

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88 C.R. - Q.5

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Tax Topics - Treaties - Articles of Treaties - Article 18 50

Clause 56(1)(a)(i)(C.1)

See Also

McKenzie v. The Queen, 2017 TCC 56 (Informal Procedure)

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Tax Topics - Income Tax Regulations - Regulation 6803 an IRA which is a custodial arrangement is included 205

Subparagraph 56(1)(a)(iii)

See Also

Scott v. The Queen, 2017 TCC 224

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Words and Phrases
in lieu of
Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 89 - Subsection 89(1) - Paragraph 89(1)(a) trust return not admitted at trial opening where no previous notice and not relied upon by CRA 211
Tax Topics - Income Tax Act - 101-110 - Section 107.1 - Paragraph 107.1(a) s. 107.1(a) in effect produced a rollover on cash distribution of mooted benefits 175
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) a distribution from a health and welfare trust to compensate for lost insurance coverage was not a taxable benefit as it did not come within s. 6(4) 304
Tax Topics - General Concepts - Stare Decisis Supreme Court obiter accorded deference 129
Tax Topics - Income Tax Act - Section 9 - Compensation Payments surrogatum principle references "why the compensatory amount was paid," and not confined to business receipts 191
Tax Topics - Statutory Interpretation - Specific v. General Provisions termination payment that did not come within s. 6(4) should be treated as excluded from s. 6(1)(a) 141

Subparagraph 56(1)(a)(ii)

Cases

Doyle v. The Queen, 83 DTC 5383, [1983] CTC 339 (FCTD)

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Lawson v. The Queen, 82 DTC 6331, [1982] CTC 368 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 21

Administrative Policy

29 April 1991 T.I. (Tax Window, No. 2, p. 21, ¶1217)

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Paragraph 56(1)(b) - Support

Cases

Tossell v. Canada, 2005 DTC 5365, 2005 FCA 223

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The Queen v. Jasper, 94 DTC 6519 (FCTD)

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Tax Topics - General Concepts - Estoppel 109

The Queen v. Sigglekow, 85 DTC 5471 (FCTD)

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The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)

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See Also

Welch v. The Queen, 2012 DTC 1288 [at 3892], 2012 TCC 350 (Informal Procedure)

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Blais v. MNR, 92 DTC 1497 (TCC)

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payment references funds transfer 94
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 94

Morley-Clarke v. Jones, [1985] BTC 460 (C.A.)

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The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)

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Articles

Durnford, Toope, "Spousal Support in Family Law and Alimony in the Law of Taxation", Canadian Tax Journal, 1994, Vol. 42, No. 1, p. 1.

Paragraph 56(1)(c)

Cases

James v. The Queen, 85 DTC 5172, [1985] 1 CTC (FCTD)

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Paragraph 56(1)(d) - Annuity payments

Cases

The Queen v. Rumack, 92 DTC 6142 (FCA)

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Wilder v. Minister of National Revenue, 52 DTC 1014, [1951] CTC 304, [1952] 1 S.C.R. 123

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See Also

Short v. The Queen, 99 DTC 1146 (TCC)

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Administrative Policy

30 March 2017 External T.I. 2015-0609951E5 F - Article 18 of the Canada-Turkey Income Tax Convention

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Tax Topics - Treaties - Articles of Treaties - Article 18 capital portion of s. 56(1)(d) is not excluded as an annuity under Canada-Turkey Treaty/RRSP annuity payments are pensions 382
Tax Topics - Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 5 - Pension RRSP annuity payments to Turkish resident were subject to Pt XIII tax as pension payments 44

20 May 1994 T.I. 940504 (C.T.O. "Structured Settlement under No-Fault Insurance")

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29 January 1993 T.I. 9200395 (Tax Window, No. 27, p. 1, ¶2360)

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22 January 1993 T.I. 9203635 (Tax Window, No. 27, p. 1, ¶2360)

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29 October 1992 T.I. 922997 (September 1993 Access Letter, p. 414, ¶C56-252)

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21 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 28, ¶1099)

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80 C.R. - Q.26

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Paragraph 56(1)(h) - Registered retirement savings plan, etc.

See Also

Maass-Howard v. The Queen, 2013 DTC 1009 [at 59], 2012 TCC 307, briefly aff'd 2013 DTC 5167 [at 6429], 2013 FCA 234

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Paragraph 56(1)(l.1) - Idem [Legal expenses]

Cases

Scharf v. Freure Homes Ltd., 95 DTC 5074 (Ont. Ct. J. (G.D.))

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Administrative Policy

8 October 1996 T.I. 962701 (C.T.O. "Loss of Employment, Mental Distress, Damages")

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Paragraph 56(1)(n) - Scholarships, bursaries, etc.

Cases

Simser v. Canada, 2005 DTC 5001, 2004 FCA 414

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Words and Phrases
bursary

The Queen v. Savage, 83 DTC 5409, [1983] CTC 393, [1983] 2 S.C.R. 428

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The Queen v. McLaughlin, 78 DTC 6406, [1978] CTC 602 (FCTD)

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See Also

Lewis v. The Queen, 2013 DTC 1117 [at 620], 2013 TCC 137 (Informal Procedure)

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Caropreso v. The Queen, 2012 DTC 1190 [at 3488], 2012 TCC 212 (Informal Procedure)

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Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)

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Chabaud c. La Reine, 2012 DTC 1076 [at 2856], 2011 TCC 438 (Informal Procedure)

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Words and Phrases
fellowship bursary

Mbarga v. The Queen, 2005 DTC 1447, 2005 TCC 595 (Informal Procedure)

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Words and Phrases
receive bursary

Simser v. The Queen, 2003 DTC 617, 2003 TCC 366

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20 June 1994 Internal T.I. 7-940939 -

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3 December 1993 T.I. 932658 (C.T.O. "Allowances Paid by CIDA to Foreign Students and Trainees")

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20 August 1992, T.I. (Tax Window, No. 23, p. 22, ¶2160)

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6 April 1992 T.I. 920399 (March 1993 Access Letter, p. 69, ¶C56-215; Tax Window, No. 18, p. 22, ¶1859)

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84 C.R. - Q.22

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Articles

Mark Dumalski, Dimitri Sarabalos, "Are Payments to Research Assistants Tax-Free?", Canadian Tax Focus, Vol. 3, No. 2, May 2013, p. 11

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Jack Bernstein, "Scholarships: The Enhanced Employee Incentive", CCH Tax Topics, No. 1909, 9 October, 2008

Paragraph 56(1)(o) - Research grants

Cases

Ghali v. Canada, 2005 DTC 5472, 2004 FCA 60

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Words and Phrases
research grant

See Also

Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)

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Chabaud c. La Reine, 2012 DTC 1076 [at 2856], 2011 TCC 438 (Informal Procedure)

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Words and Phrases
research grant

Administrative Policy

31 July 2014 External T.I. 2013-0509291E5 - Research grants

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Paragraph 56(1)(r) - Financial assistance

Administrative Policy

17 July 2015 External T.I. 2014-0517091E5 - Wage Subsidies

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) federal assistance to those with disabilities 143

4 March 2015 Internal T.I. 2014-0527751I7 F - Soutien de revenu accordé aux individus

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Paragraph 56(1)(u) - Social assistance payments

Cases

Simser v. Canada, 2005 DTC 5001, 2004 FCA 414

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17 July 2015 External T.I. 2014-0517081E5 - Assistance for individuals with disabilities

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) federal assistance to those with disabilities 144

29 July 2015 External T.I. 2015-0575631E5 - social assistance

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Tax Topics - Income Tax Act - Section 3 payments in kind by social assistance organization 81
Tax Topics - Income Tax Regulations - Regulation 233 - Subsection 233(2) potential exclusion of payments in kind 245

14 February 2014 Internal T.I. 2013-0495661I7 - Taxability of payment from US charitable trust

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) financial assistance to former charity employee 86

13 January 1992 T.I. (Tax Window, No. 15, p. 21, ¶1696)

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16 August 1991 T.I. (Tax Window, No. 7, p. 16, ¶1394)

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7 September 89 Memorandum (February 1990 Access Letter, ¶1121)

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Paragraph 56(1)(v) - Workers’ compensation

Cases

Canada v. Whitney, 2002 DTC 7145, 2002 FCA 266

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Administrative Policy

IT-202R2 "Employees' or Workers' Compensation

13 November 1992 T.I. 922953 (September 1993 Access Letter, p. 414, ¶C56-253)

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Paragraph 56(1)(x) - Retirement compensation arrangement

Administrative Policy

8 June 1993 Memorandum (Tax Window, No. 32, p. 17, ¶2614)

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6 August 1991 T.I. (Tax Window, No. 8, p. 7, ¶1421)

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Subsection 56(2) - Indirect payments

Cases

Lambert v. Canada, 2005 DTC 5499, 2004 FCA 389

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James v. Canada, 2001 DTC 5075 (FCA)

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Neuman v. M.N.R., 98 DTC 6297, [1998] 1 S.C.R. 770

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Tax Topics - Statutory Interpretation - Provincial Law 53

Jones v. The Queen, 96 DTC 6016 (FCA)

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Words and Phrases
desire
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Resolving Ambiguity 71

Smith v. The Queen, 93 DTC 5351 (FCA)

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Dixon v. Deputy Attorney General of Canada, 91 DTC 5584 (Ont HCJ.)

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The Queen v. Fairey, 91 DTC 5230 (FCTD)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 70

McClurg v. Canada, 91 DTC 5001, [1990] 3 S.C.R. 1020

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Winter v. The Queen, 90 DTC 6681 (FCA)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) s. 56(2) applied to taxpayer rather than 15(1) to son-in-law as de minimis shareholder 70
Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) 96

R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.)

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Tax Topics - Other Legislation/Constitution - Constitution Act, 1982 - Subsection 15(1) 45
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) benefit based on actual rather than subjective value 91

Boardman v. The Queen, 85 DTC 5628, [1986] 1 CTC 103 (FCTD)

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The Queen v. Hoffman, 85 DTC 5508, [1985] 2 CTC 347 (FCTD)

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De Groote v. The Queen, 85 DTC 5008, [1985] 1 CTC 687 (FCTD)

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The Queen v. Chrapko, 84 DTC 6544, [1984] CTC 594 (FCTD), rev'd 88 DTC 6487, [1988] 2 CTC 342 (FCA)

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Barbeau v. The Queen, 81 DTC 5379, 84 DTC 6148, [1981] CTC 496 (FCTD)

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Champ v. The Queen, 83 DTC 5029, [1983] CTC 1 (FCTD)

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Cox v. The Queen, 82 DTC 6287, [1982] CTC 322 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Compensation Payments 84

Fraser Companies, Ltd. v. The Queen, 81 DTC 5051, [1981] CTC 61 (FCTD)

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Murphy v. The Queen, 80 DTC 6314, [1980] CTC 386 (FCTD)

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McClain Industries of Canada Inc. v. The Queen, 78 DTC 6356, [1978] CTC 511 (FCTD)

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Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)

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Nelson v. The Queen, 74 DTC 6266, [1974] CTC 360 (FCA)

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Tax Topics - General Concepts - Effective Date 185

The Queen v. Quinn, 73 DTC 5215, [1973] CTC 258 (FCTD)

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See Also

Gainor v. The Queen, 2011 DTC 1317 [at 1798], 2011 TCC 442

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Tax Topics - Income Tax Act - Section 9 - Nature of Income 162

Delso Restoration Ltd. v. The Queen, 2011 DTC 1315 [at 1786], 2011 TCC 435 (Informal Procedure)

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D'Andrea v. The Queen, 2011 DTC 1234 [at 1356], 2011 TCC 298

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) fraud conviction did not establish neglectful reporting 183

Sochatsky v. The Queen, 2011 DTC 1065 [at 346], 2011 TCC 41, 2012 TCC 65

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Tax Topics - General Concepts - Payment & Receipt bonus booked as loan back/constructive receipt 129
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 182

GlaxoSmithKline Inc. v. The Queen, 2008 DTC 3957, 2008 TCC 324

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Laflamme v. The Queen, 2008 DTC 482, 2008 TCC 255

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Tax Topics - General Concepts - Fair Market Value - Shares 196

Ceco Operations Ltd. v. The Queen, 2006 DTC 3006, 2006 TCC 256

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Tax Topics - General Concepts - Substance 95
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 266
Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) partnership subscription for taxpayer affiliate pref shares not boot 259

Speer v. The Queen, 99 DTC 157 (TCC)

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Ferrel v. The Queen, 97 DTC 1565 (TCC)

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Gilvesy v. The Queen, 96 DTC 1417 (TCC)

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Tax Topics - General Concepts - Fair Market Value - Other 51

Paxton v. The Queen, 95 DTC 179 (TCC), rev'd 97 DTC 5012 (FCA)

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Placements T.S. Inc. v. The Queen, 94 DTC 1302 (TCC)

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Béliveau v. MNR, 91 DTC 669 (TCC)

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Simon-Carves of Canada Ltd. v. MNR, 89 DTC 98 (TCC)

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Administrative Policy

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

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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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense where rental lands purchased subject to obligation to pay the rents to vendor, no income inclusion and deduction of the rents by the purchaser under ss. 9 and 18(1)(a) 83
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

6 December 2016 External T.I. 2016-0666841E5 F - Sale of property for POD less than FMV

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) application to Holdco shareholder of Opco where Opco conferrred a benefit on child of Holdco's shareholder 200
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 246(1) applicable to indirect shareholder benefit if direct shareholder influenced the benefit conferral 193

14 March 2016 External T.I. 2016-0626781E5 - Neuman Type Situation

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) might apply where spouse subscribes nominal consideration for Opco shares and receives a large discretionary dividend 214
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) Kieboom treated as entailing disposition of right to receive dividends 316
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) spousal rollover for Kieboom disposition of economic interest 68

24 June 2015 External T.I. 2015-0575911E5 F - Benefit to shareholder or conferred on a person

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) benefit only conferred on one shareholder (the husband) if wife of one of four sibling shareholders receives benefit 303
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) benefit conferred on spouse of individual shareholder of parent 137

S2-F3-C1 - Payments from Employer to Employee

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10 April 2014 External T.I. 2013-0514321E5 - Donated vacation

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) donated vacation/no double taxation 162

13 March 2014 External T.I. 2013-0510791E5 - Non-cash long-service award and cash donation

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11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder 109
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder 169
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 218
Tax Topics - Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 216
Tax Topics - General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV 128
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 157

27 February 2014 External T.I. 2013-0506401E5 - Loan from a partnership to an individual

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) partnership to partner shareholder loan 63

15 November 2013 Internal T.I. 2013-0478621I7 F - Transfer of intangibles - TP adjustments

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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) group sale with Canco not charging for intangibles 140
Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) must engage direct parent 146

10 July 2013 Internal T.I. 2013-0475501I7 F - Amounts returned to trustee/beneficiary

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) distributions to children immediately paid to father 166
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) distributions to children immediately paid to father 166
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) distributions to children immediately paid to father 164
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) distributions to children immediately paid to father 138

19 August 2013 External T.I. 2013-0488011E5 - Real Estate Referral Fees

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6 December 2012 External T.I. 2012-0461711E5 F - Paiements indirects / Indirect payments

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30 October 2012 Ontario CTF Roundtable, 2012-0462891C6 - Application of 56(2) to discretionary trust

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20 November 2012 Internal T.I. 2011-0416761I7 - Non-Resident, Part XIII Tax

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25 September 2012 BC Tax Conference Roundtable, 2012-0457551C6 - Application of 56(2) to discretionary trust

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1998 Strategy Institute Round Table, No. 981310

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29 October 1996 T.I. 963032 (C.T.O. "Trustee Directing Payment or Right to Income")

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30 October 1995 Internal T.I. 7-951631 -

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2 June 1995 T.I. 950375 ("Charitable Gift Annuity in RRSP")

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) 27

2 November 1994 Memorandum 942044 (C.T.O. "Redirection of Salary During a Strike")

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28 October 1994 T.I. 940246 (C.T.O. "Non-Capital Losses and Corp. Debt")

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17 May 1993 Memorandum (Tax Window, No. 32, p. 2, ¶2592)

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11 May 1994 Memorandum 932735 (C.T.O. "IAAC Payments Applied to a Loan after Bankrupt Discharged")

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92 C.R. - Q.22

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 27

92 C.R. - Q.22

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 54

24 February 1992 Memorandum (Tax Window, No. 13, p. 12, ¶1628)

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13 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 9, ¶1044)

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23 March 1990 T.I. (August 1990 Access Letter)

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14 July 1989 Inter-Divisional Memorandum (Dec. 89 Access Letter, ¶1045)

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87 C.R. - Q.72

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86 C.R. -Q.40

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86 C.R. - Q.41

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85 C.R. - Q.6

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 13

84 C.R. - Q.24

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84 C.R. - Q.82

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Tax Topics - Income Tax Act - Section 67 54

81 C.R. - Q.26

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79 C.R. - Q.19

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IT-468R "Management or Administration Fees Paid to Non-Residents"

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IT335R2 "Indirect Payments" 12 July 2004

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Articles

Bowman, "New Wine in Old Bottles - Using Personal Trusts as Business Vehicles", Business Vehicles, Vol. III, No. 1, 1996, p. 114

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Beam, Laiken, "Recent Developments on Subsection 56(2): Indirect Payments", 1995 Canadian Tax Journal, Vol. 43, No. 2, p. 447.

Subsection 56(3) - Exemption for scholarships, fellowships, bursaries and prizes

See Also

Huang v. The Queen, 2012 DTC 1120 [at 3103], 2012 TCC 81 (Informal Procedure)

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Words and Phrases
student

Subsection 56(3.1) - Limitations of scholarship exemption

Paragraph 56(3.1)(b)

Administrative Policy

20 August 2014 External T.I. 2014-0529481E5 - Scholarship exemption

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Subsection 56(4) - Transfer of rights to income

Cases

Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)

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Words and Phrases
rent

De Groote v. The Queen, 85 DTC 5008, [1985] 1 CTC 687 (FCTD)

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Fraser Companies, Ltd. v. The Queen, 81 DTC 5051, [1981] CTC 61 (FCTD)

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The Queen v. Canadian-American Loan and Investment Corp. Ltd., 74 DTC 6104, [1974] CTC 101 (FCTD)

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Tax Topics - General Concepts - Payment & Receipt receipt of sums collected by affiliate 143

The Queen v. Burns, 73 DTC 5219, [1973] CTC 264 (FCTD)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 60

See Also

Howard v. Commissioner of Taxation, [2014] HCA 21

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) damages not received as constructive trustee as not received qua director 183
Tax Topics - Income Tax Act - Section 9 - Compensation Payments damages not corporate income as not received qua director 183
Tax Topics - Income Tax Act - Section 9 - Nature of Income agreement assigned rights to proceeds of law suit rather than entitlement under law suit 305

Boutilier v. The Queen, 2007 DTC 479, 2007 TCC 96

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MFC Bancorp Ltd. v. The Queen, 99 DTC 905 (TCC)

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Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) largely overlapping boards of directors and substantial minority interest 78

Ferrel v. The Queen, 97 DTC 1565 (TCC)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 132

Placements T.S. Inc. v. The Queen, 94 DTC 1302 (TCC)

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Sazio v. MNR, 69 DTC 5001 (Ex Ct)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 146

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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense where rental lands purchased subject to obligation to pay the rents to vendor, no income inclusion and deduction of the rents by the purchaser under ss. 9 and 18(1)(a) 83
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

11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder 109
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder 164
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 218
Tax Topics - Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 216
Tax Topics - General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV 128
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 157

29 April 2003 External T.I. 2003-00646 -

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8 September 1997 External T.I. 5-970715 -

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3 February 1994 External T.I. 5-923647 -

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) 19

3 December 1993 T.I. 920099 (C.T.O. "Transfer of Farm Inventory to a Corporation")

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Tax Topics - General Concepts - Fair Market Value - Other 64

Subsection 56(4.1) - Interest free or low interest loans

Administrative Policy

92 C.R. - Q.7

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91 C.R. - Q.5

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8 May 1990 T.I. (October 1990 Access Letter, ¶1461)

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89 C.R. - Q.47

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88 C.R. - "Finance and Leasing" - "Interest" - "Loans to Non-Arm's Length Parties"

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Articles

Joseph Frankovic, "Income Splitting and Attribution", Tax Topics, Wolters Kluwer, No. 2250, April 23, 2015

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Emes, "Planning for Immigration to Canada from Countries other than the United States", 1993 Corporate Management Tax Conference Report, c. 13.

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Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) 4

Brahmst, "Subsection 56(4.1) - An Update", Canadian Current Tax, January 1992, p. P47.

Subsection 56(12) - Foreign retirement arrangement

Cases

Serra v. Canada, 98 DTC 6602 (FCA)

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The Queen v. Arsenault, 96 DTC 6131 (FCA)

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 58