Nature of Income

Commentary

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Cases

Minet Inc. v. The Queen, 98 DTC 6364 (FCA)

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Leonard Pipeline Contractors Ltd. v. The Queen, 98 DTC 6134 (FCTD)

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The Queen v. Foothills Pipe Lines (Yukon) Ltd., 90 DTC 6607 (FCA)

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Ablan Leon (1964) Ltd. v. MNR, 76 DTC 6280, [1976] CTC 506 (FCA)

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Perrault v. The Queen, 76 DTC 6021, [1976] CTC 65 (FCTD), aff'd 78 DTC 6272, [1978] CTC 395 (FCA)

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Wipf v. The Queen, 75 DTC 5034, [1975] CTC 79 (FCA), aff'd 76 DTC 6059, [1976] CTC 57 [1970] S.C.R. 958

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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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Locations of other summaries Wordcount
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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MNR v. Gault, 65 DTC 5157, [1965] CTC 261 (Ex Ct)

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Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC)

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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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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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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.)

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Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82

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Bouck v. Minister of National Revenue, 52 DTC 1090, [1952] CTC 90, [1952] 2 S.C.R. 17

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B & B Royalties, Ltd. v. MNR, [1940-1941] CTC 65 (Ex Ct)

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See Also

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

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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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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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)

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Hadlee v. C.I.R., [1993] 2 WLR 696 (PC)

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Honeybunch Bakeries (Saskatoon 1975) Ltd. v. MNR, 90 DTC 1549 (TCC)

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Canpar Holdings Ltd. v. Saskatchewan (Minister of Energy and Mines) (1987), 60 Sask R 128 (C.A.)

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Ages v. MNR, 71 DTC 86 (TAB)

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Morley v. Messrs. Tattersall (1938), 22 TC 51 (CA)

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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 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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Locations of other summaries Wordcount
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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Locations of other summaries Wordcount
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

6 September 1994 T.I. 941083 (C.T.O. "Life Insurance Commissions:)

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18 March 1992 T.I. (Tax Window, No. 18, p. 15, ¶1815)

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27 August 1991 Memorandum (Tax Window, No. 8, p. 22, ¶1414)

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6 May 1991 T.I. (Tax Window, No. 3, p. 27, ¶1240)

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