Cases
Minet Inc. v. The Queen, 98 DTC 6364 (FCA)
Leonard Pipeline Contractors Ltd. v. The Queen, 98 DTC 6134 (FCTD)
The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 135 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 89 |
Ablan Leon (1964) Ltd. v. MNR, 76 DTC 6280, [1976] CTC 506 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 77 | |
| Tax Topics - Income Tax Act - Section 96 | 27 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 95 |
Perrault v. The Queen, 76 DTC 6021, [1976] CTC 65 (FCTD), aff'd 78 DTC 6272, [1978] CTC 395 (FCA)
Wipf v. The Queen, 75 DTC 5034, [1975] CTC 79 (FCA), aff'd 76 DTC 6059, [1976] CTC 57 [1970] S.C.R. 958
Philp v. MNR, 70 DTC 6237, [1970] CTC 330 (Ex Ct)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 - Expense Reimbursement | 132 |
Minister of National Revenue v. Atlantic Engine Rebuilders Ltd., 67 DTC 5155, [1967] CTC 230, [1967] S.C.R. 477
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| Tax Topics - Income Tax Act - Section 9 - Timing | deposits returned if future supply | 150 |
Premium Iron Ores Ltd. v. Minister of National Revenue, 66 DTC 5280, [1966] CTC 391, [1966] S.C.R. 685
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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 | legal exepnses incurred in challenging US assessments - deductible | 136 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 94 |
MNR v. Gault, 65 DTC 5157, [1965] CTC 261 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | 75 |
Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | bonuses or discounts not interest where market interest coupons | 229 |
| Tax Topics - Income Tax Act - Section 76 | 121 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Loans | 111 | |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 170 |
Woodward's Pension Society v. The Minister of National Revenue, 62 DTC 1002, [1962] CTC 11, [1962] S.C.R. 224
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| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | 201 |
Minister of National Revenue v. St. Catharines Flying Training School Ltd., 55 DTC 1145, [1955] CTC 185, [1955] S.C.R. 738
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| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | 176 |
Wilson v. Minister of National Revenue, 55 DTC 1065, [1955] CTC 87, [1955] S.C.R. 352
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Canadian Fruit Distributors Ltd. v. MNR, 54 DTC 1145, [1954] CTC 284 (Ex. Ct.)
Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 47 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 46 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Deposits | 65 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | deposit excluded | 76 |
See Also
Victoria Power Networks Pty Ltd v Commissioner of Taxation, [2019] FCA 77
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | additonal customer connection charges to cover loss were income receipts | 197 |
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 56 - Subsection 56(4) | agreement assigned rights to proceeds of law suit rather than entitlement under law suit | 305 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | damages not corporate income as not received qua director | 183 |
Gainor v. The Queen, 2011 DTC 1317 [at 1798], 2011 TCC 442
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 168 |
On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at 4243], 2010 TCC 475
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | parol evidence rule applied to Minister | 106 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 42 |
Wabush Iron Company Limited v. The Queen, 2009 DTC 814, 2009 TCC 239
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Morisset c. La Reine, 2008 DTC 3864, 2006 TCC 483
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Dello v. The Queen, 2003 DTC 788, 2003 TCC 392
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Whittles v. Uniholdings Ltd. (No. 3), [1995] BTC 119 (Ch. D.)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 202 |
Conforbel Canada Ltée, 94 DTC 1190 (TCC)
Hadlee v. C.I.R., [1993] 2 WLR 696 (PC)
Honeybunch Bakeries (Saskatoon 1975) Ltd. v. MNR, 90 DTC 1549 (TCC)
Canpar Holdings Ltd. v. Saskatchewan (Minister of Energy and Mines) (1987), 60 Sask R 128 (C.A.)
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | 69 |
Ages v. MNR, 71 DTC 86 (TAB)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 138 |
Administrative Policy
18 May 2011 Internal T.I. 2010-0380391I7 F - Convention entre des co-propriétaires
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5 October 2018 APFF Roundtable Q. 16, 2018-0768871C6 F - Dépenses de bureau à domicile et d’automobile
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) | example of proration of capped s. 13(7)(g) capital cost | 143 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | capital cost of co-ownership interest | 62 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | depreciable property must be owned | 66 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | payment of expenses of taxpayer by another does not preclude “incurring” by taxpayer | 161 |
28 October 2016 External T.I. 2016-0654331E5 F - Transfer of rights to income
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|---|---|---|
| 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 |
| 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 |
30 March 2016 Internal T.I. 2014-0547931I7 F - Voyages offerts par une compagnie
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| Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(1) | company providing free trips to incorporated sales reps is required to T4A the individuals if they received the trip qua employee (but not shareholder) of their corporation | 166 |
S2-F1-C1 - Health and Welfare Trusts
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15 September 2014 Internal T.I. 2014-0545001I7 - Grants paid to employers of reservists
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | compensation for reservist costs | 38 |
18 December 2013 Internal T.I. 2012-0472211I7 F - Voyages offerts par une compagnie
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | Caribbean sales incentive trip provided to incorporated sales reps represents a benefit to them from their corporation | 382 |
| Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(d) | Caribbean sales incentive trip provided to incorporated sales reps excluded if s. 6(1)(a) benefit to them qua employee | 168 |
| Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(4) - Paragraph 67.1(4)(b) | Caribbean sales incentive trip is "entertainment" | 171 |
11 October 2013 Roundtable, 2013-0495701C6 F - Financement participatif
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17 October 2011 External T.I. 2011-0423361E5 F - Loi sur le courtage immobilier
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| Tax Topics - General Concepts - Illegality | Quebec real estate brokers can earn their remuneration through a corporation | 145 |
14 March 2011 External T.I. 2010-0382091E5 F - Revenu d'entreprise exploitée activement
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29 October 2010 External T.I. 2009-0347791E5 F - Somme reçue par une société
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Words and Phrases
royalty6 September 1994 T.I. 941083 (C.T.O. "Life Insurance Commissions:)
18 March 1992 T.I. (Tax Window, No. 18, p. 15, ¶1815)
27 August 1991 Memorandum (Tax Window, No. 8, p. 22, ¶1414)
6 May 1991 T.I. (Tax Window, No. 3, p. 27, ¶1240)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 57 |
Articles
John Tobin, "Infrastructure and P3 Projects", 2017 Conference Report (Canadian Tax Foundation), 10:1-31
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Commentary