Expense Reimbursement

Cases

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 - Exempt Receipts/Business 27

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 86

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 140

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 67

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 52

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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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Berhad v. Director General of Inland Revenue, [1985] BTC 578 (PC)

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A receipts during development reduced cost rather than being income 46

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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 - Exempt Receipts/Business incentive trip to Bahamas 132
Tax Topics - Income Tax Act - Section 9 - Nature of Income incentive trip to Bahamas 132

See Also

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 - Exempt Receipts/Business 55

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 23

Campbell v. MNR, 92 DTC 1855 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 88

Fleur de Lys Warehousing Ltd. v. MNR, 91 DTC 1343 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Timing 55

Buckman v. MNR, 91 DTC 1249 (TCC)

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Molony v. MNR, 90 DTC 1394 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 29

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 23

Potvin v. MNR, 90 DTC 1644 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 37

Hall v. MNR, 90 DTC 1431 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 67

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

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Commissioner of Taxation of the Commonwealth of Australia v. Rowe (1995), 60 FCR 99, 95 ATC 4691, [1995] 31 ATR 392.

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Administrative Policy

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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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 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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 - Exempt Receipts/Business 32

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

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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 - Exempt Receipts/Business 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 - Exempt Receipts/Business 39

86 C.R. - Q.7

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 13

9 November 1981 TI 5-3119

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business 36

Articles

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

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