Cases
Minet Inc. v. The Queen, 98 DTC 6364, [1998] 3 CTC 352 (FCA)
Leonard Pipeline Contractors Ltd. v. The Queen, 98 DTC 6134 (FCTD)
The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607, [1990] 2 CTC 448 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 139 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 95 |
Ablan Leon (1964) Ltd. v. MNR, 76 DTC 6280, [1976] CTC 506 (FCA)
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|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 79 | |
| Tax Topics - Income Tax Act - Section 96 | 31 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 101 |
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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|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | sales incentives paid to 3rd-party employees were taxable benefits | 129 |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | incentive trip to Bahamas | 134 |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 134 |
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 | 152 |
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 | 144 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 100 |
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) | 77 |
Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | bonuses or discounts not interest where market interest coupons | 239 |
| Tax Topics - Income Tax Act - Section 76 | 127 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Loans/receivables | 113 | |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 176 |
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) | 207 |
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) | 180 |
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 | 51 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 52 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Deposits | 73 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | deposit excluded | 78 |
See Also
Victoria Power Networks Pty Ltd v Commissioner of Taxation, [2019] FCA 77
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| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | additonal customer connection charges to cover loss were income receipts | 205 |
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 | 191 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | agreement assigned rights to proceeds of law suit rather than entitlement under law suit | 344 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | damages not corporate income as not received qua director | 191 |
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) | 174 |
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 | 114 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 44 |
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 | |
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 210 |
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, [1990] 2 CTC 2148 (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) | 77 |
Ages v. MNR, 71 DTC 86 (TAB)
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 144 |
Administrative Policy
26 August 2005 Internal T.I. 2005-0121871I7 F - Assurance-vie commissions reçues par une société
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21 November 2008 External T.I. 2008-0279231E5 F - Revenu de commission
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S4-F14-C1 - Artists and Writers
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8 February 2010 External T.I. 2009-0337691E5 F - Assurance frais-généraux
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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 | 151 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | capital cost of co-ownership interest | 68 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | depreciable property must be owned | 72 |
| 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 | 169 |
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) | 89 |
| 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 | 169 |
| 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 | 168 |
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 | 174 |
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 | 40 |
18 December 2013 Internal T.I. 2012-0472211I7 F - Voyages offerts par une compagnie
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| 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 | 392 |
| 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 | 178 |
| Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(4) - Paragraph 67.1(4)(b) | Caribbean sales incentive trip is "entertainment" | 175 |
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 | 155 |
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
royalty28 September 2010 External T.I. 2010-0357141E5 F - Prix de présence et tirages
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | promotional prize as income to employee of third party | 155 |
12 June 2009 Internal T.I. 2008-0294921I7 F - Montant reçu à l'égard d'un surplus actuariel
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | transfer of a pension plan assets and liabilities to the asset purchaser with regulatory approval entailed a plan “modification” rendering actuarial surplus compensation taxable | 292 |
6 September 1994 Internal T.I. 9410837 - LIFE INSURANCE COMMISSIONS
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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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| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 59 |
Articles
John Tobin, "Infrastructure and P3 Projects", 2017 Conference Report (Canadian Tax Foundation), 10:1-31
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Commentary