Exempt Receipts/Business

Cases

Morguard Corporation v. Canada, 2013 DTC 5009 [at 5554], 2012 FCA 306

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Canada v. Johnson, 2013 DTC 5004 [at 5515], 2012 FCA 253

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) failure to seek confirmatory independent advice 196
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit contractual payments derived from Ponzi scheme were income 249

2529-1915 Québec Inc. v. Canada, 2009 DTC 5023 [at 5585], 2008 FCA 398

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Tax Topics - General Concepts - Sham capital dividend elections for distributions of what should have been known to be income-account gains were shams 245
Tax Topics - General Concepts - Tax Avoidance capital dividend elections for distributions of what should have been known to be income-account gains were shams 245
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business shares premiums received for marketing tax scheme were business income 196
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2) capital dividend elections for distributions of what should have been known to be income-account gains were shams 656
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares shares acquired for immediate resale as part of capital dividend account generation scheme were on income account 160

Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128, rev'd 2003 DTC 5225, 2003 FCA 128

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Bellingham v. The Queen, 96 DC 6075 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 27

The Queen v. TCG International Inc., 96 DTC 6547 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement tenant inducement 98

Harrowston Corp. v. The Queen, 96 DTC 6544 (FCA)

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Winemaker v. The Queen, 96 DTC 6040 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement gift rceeived in course of business 86

The Queen v. Remington, 94 DTC 6549 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 141

R. v. Fogazzi, 93 DTC 5183 (Ont CA)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 67

Johnson & Johnson Inc. v. The Queen, 92 DTC 6373 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 52

Suzy Creamcheese (Canada) Ltd. v. The Queen, 92 DTC 6291 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 60

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

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Inshore Investments Ltd. v. The Queen, 92 DTC 6162 (FCTD)

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Kay v. Coffin, 91 DTC 5350 (Ont HCJ.)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 12

Woodward Stores Ltd. v. The Queen, 91 DTC 5090 (FCTD)

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Balanko v. MNR, 88 DTC 6228, [1988] 1 CTC 317 (FCTD)

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French Shoes Ltd. v. The Queen, 86 DTC 6359, [1986] 2 CTC 132 (FCTD)

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R. v. Christensen, 83 DTC 5359 (BCSC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 11

The Queen v. Cranswick, 82 DTC 6073, [1982] CTC 69 (FCA)

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The Queen v. Audet, 78 DTC 6554, [1978] CTC 788 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 25

Alberta Gas Trunk Line Co. Ltd. v. Minister of National Revenue, [1972] S.C.R. 498, 71 DTC 5403, [1971] CTC 723

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Philp v. MNR, 70 DTC 6237, [1970] CTC 330 (Ex Ct)

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) sales incentives paid to 3rd-party employees were taxable benefits 127
Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 132
Tax Topics - Income Tax Act - Section 9 - Nature of Income incentive trip to Bahamas 132

MNR v. Eldridge, 64 DTC 5338, [1965] 1 Ex. C.R. 758

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See Also

Hakki v. Secretary of State for Work and Pensions & Anor, [2014] BTC 22, [2014] EWCA Civ 530

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Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit careful and successful poker playing was not a trade or business 124

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) required transfer of value between subs not a benefit 198

Bégin v. The Queen, 2012 DTC 1111 [at 3061], 2012 TCC 18 (Informal Procedure)

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Peek v. The Queen, 2007 DTC 602, 2007 TCC 152

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Leblanc v. The Queen, 2007 DTC 307, 2006 TCC 680

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Pellerin c. La Reine, 2006 DTC 3341, 2006 TCC 383 (Informal Procedure)

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Rocovitis v. Dominion of Canada General Insurance Co. (2005), 63 OR (3d) 402 (CA)

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656203 Ontario Inc. v. The Queen, 2003 DTC 405, 2003 TCC 264

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Ipsco Inc. v. The Queen, 2002 DTC 1421 (TCC)

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C.I.R. (New Zealand) v. Wattie & Anor., [1998] BTC 438 (PC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 55

Frank Beban Logging Limited v. The Queen, 98 DTC 1393 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 39

Fortino v. The Queen, 97 DTC 55 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)

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Murray Barrett Ltd. v. MNR, 94 DTC 1886 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 23

Campbell v. MNR, 92 DTC 1855 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 88

Buckman v. MNR, 91 DTC 1249 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 9

Molony v. MNR, 90 DTC 1394 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 29

IRC v. Aken, [1990] BTC 352 (C.A.)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 23

Potvin v. MNR, 90 DTC 1644 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 37

Hall v. MNR, 90 DTC 1431 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 56

Mackenzie v. Arnold (1952), 33 TC 363 (C.A.)

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Commissioner of Income Tax (Queensland) v. The Bank of New South Wales (1913), 16 C.L.R. 504 (HC of A.)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 67

Higgs v. Olivier (1952), 33 TC 136 (C.A.)

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Minister of Finance v. Smith, [1927] A.C. 193 (PC)

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Administrative Policy

7 May 2014 Ministerial Correspondence 2014-0525991M4 - Tax Treatment of Monetary Inheritances

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21 August 2014 Internal T.I. 2014-0542121I7 - Payments from the province of BC

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Tax Topics - Income Tax Act - Section 63 - Subsection 63(1) - Paragraph 63(1)(d) parent compensation for teachers' strike 154

18 August 2014 External T.I. 2014-0528171E5 - Condominium Corporations and 149(1)(l)

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Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) condominium solar revenue treated as members' income 238

15 July 2014 Internal T.I. 2014-0527761I7 - Macau Wealth Sharing Scheme

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8 July 2013 Internal T.I. 2012-0472651I7 F - Crédit pour l'embauche par les petites entreprises

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Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(3) - Paragraph 118.2(3)(b) small business job credit received for personal-care workers was “reimbursement” 125
Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(b.1) single service does not qualify as attendant care 68

28 March 2014 External T.I. 2013-0514361E5 - XXXXXXXXXX pension

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23 April 2014 Ministerial Correspondence 2014-0522731M4 - Lottery Commissions

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25 October 2013 External T.I. 2013-0508971E5 - Crowdfunding

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8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose non-deductibility of disability insurance premiums 357

29 October 2013 External T.I. 2013-0509101E5 - Crowdfunding

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16 August 2013 External T.I. 2013-0484941E5 - Crowdfunding

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12 March 2012 External T.I. 2011-0425361E5 F - Assistance paid by franchisor

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28 February 2005 External T.I. 2004-0108551E5 - Disability Insurance Through a Professional Assoc.

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17 February 2005 External T.I. 2004-010473 -

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14 November 2000 External T.I. 2000-005292 -

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 7

1997 Ruling 970913

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9 September 1994 Memorandum 942195 (C.T.O. "Deductibility of Deep Discounts as Interest and IT-114")

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15 August 1994 T.I. 941280 (C.T.O. "Structured Settlements")

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 61

14 June 1994 Memorandum 941394 (C.T.O. "Voluntary Payments to a Priest")

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 53

13 June 1994 T.I. 933513 (C.T.O. "Taxation of Settlement Proceeds")

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 71

4 February 1993 T.I. (Tax Window, No. 29, p. 20, ¶2435)

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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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12 October 1992 External T.I. 5-922359 -

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31 July 1992 External T.I. 5-911918 -

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4 May 1992 TI 920636

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16 March 1992 T.I. (Tax Window, No. 18, p. 15, ¶1807)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 32

11 October 1991 T.I. (Tax Window, No. 11, p. 23, ¶1521)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 47

19 and 22 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 14, ¶1124)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 49

ATR-40 (18 March 1991) "Structured Settlements"

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31 May 1990 T.I. (October 1990 Access Letter, ¶1468)

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3 May 1989 Directive ASG-89-18 (June 1990 Access Letter, ¶1289)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 34

14 December 89 T.I. (May 1990 Access Letter, ¶1201)

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19 September 89 T.I. (February 1990 Access Letter, ¶1102)

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88 C.R. - F.Q.4

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 39

86 C.R. - Q.7

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 13

9 November 1981 TI 5-3119

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 36

IT-114 — Discounts, premiums and bonuses on debt obligations

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Articles

Benjamin Alarie, "The Taxation of Winnings from Poker and Other Gambling Activities in Canada", 2011 Canadian Tax Journal, Vol 59, p. 731, at p. 757

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Lewis, "The Taxation of Structured Settlements", British Tax Review, 1994, No. 1, p. 19

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