Cases
The Queen v. Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)
It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Sham | no sham as purported legal rights were created | 117 |
| Tax Topics - General Concepts - Tax Avoidance | no sham as purported legal rights were created | 117 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 117 |
The Queen v. Daly, 81 DTC 5197, [1981] CTC 270 (FCA)
The purported interposition between the taxpayer and his employer of a management corporation was legally ineffective, and thus, also ineffective...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Tax Avoidance | 92 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 86 |
Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)
A partnership of two dentists determined that the value of administrative services performed by them was $20,000, and "by means of" appropriate...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | payment by mutual book entry | 280 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 103 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 103 |
Dominion Bridge Co. Ltd. v. The Queen, 75 DTC 5150, [1975] CTC 263, aff'd 77 DTC 5367, [1977] CTC 554 (FCA)
The amounts paid by a wholly-owned Bermudan subsidiary ("Span") for purchases of steel were found to constitute the taxpayer's cost of that steel,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Tax Avoidance | 102 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 105 |
Holmes v. The Queen, 74 DTC 6143, [1974] CTC 156 (FCTD)
The wives of the partners of a law firm incorporated a company ("Irish") which acquired all the equipment and furniture of the partnership,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 126 | |
| Tax Topics - Income Tax Act - Section 245 - Old | 34 |
See Also
Trudel-Leblanc v. The Queen, 2004 DTC 3188
Although on the advice of her accountants, the taxpayer, who previously had carried on her pharmacy practice as a sole proprietor, caused a...
Harvey v. R., 98 DTC 1089, [1997] 3 C.T.C. 3022 (TCC)
The taxpayer was allowed to deduct fees charged to his dental practice equal to 115% of the eligible costs specified in a May 1985 letter of the...
Administrative Policy
25 March 1996 External T.I. 9608245 - MANAGEMENT COMPANY FEES
In response to an inquiry as to what percentage of mark-up on cost Revenue Canada would accept as a reasonable management fee corporate expense...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 48 |
21 October 1991 TI 912692 (Tax Window, No. 12, p. 22, 1545)
Management fees paid by a professional practitioner to a related corporation generally will be considered deductible if they do not exceed 115% of...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 49 |
19 September 1990 TI 902240
Where, in order to avoid GST on services provided by a management services corporation for a professional practice, the employees work directly...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 74 |
85 CR - Q.18
RC will regard fees charged by a management services corporation as reasonable if they do not exceed 115% of the cost of providing the management...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 40 |
84 CR - Q.76
The reasonableness of service fees charged by management companies is determined by RC in light of all the facts and circumstances, and no...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 29 |
IT-189R2 "Corporations Used by Practising Members of Professions"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Related Companies | 0 |