Timing

Cases

Kruger Incorporated v. Canada, 2016 FCA 186

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory derivatives not held for resale are not inventory 175
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) Minister implicitly directed to reduce taxpayer's income below that originally filed 100

Urbandale Realty Corp. Ltd. v. The Queen, 2000 DTC 6118 (FCA)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) 58

Canada v. Canada Safeway Limited, 98 DTC 6060 (FCA)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) sales tax refund not reimbursement 102

Toronto College Park Ltd. v. Canada, [1998] 1 S.C.R. 183

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Ikea Ltd. v. Canada, 98 DTC 6092, [1998] 1 S.C.R. 196

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Tax Topics - Income Tax Act - Section 9 - Compensation Payments tenant inducement payment was received in course of retail store operations 130
Tax Topics - Statutory Interpretation - Symmetry 28

Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147

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Tax Topics - General Concepts - Onus 105
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) 57
Tax Topics - Income Tax Act - Section 9 - Accounting Principles not following matching principle accorded with well-accepted business practices 153

The Queen v. Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA)

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Friedberg v. Canada, 93 DTC 5507, [1993] 4 S.C.R. 285, [1993] 2 CTC 306

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West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023, [1992] 1 CTC 15 (FCA)

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R. v. Fogazzi, 92 DTC 6421, [1992] 2 CTC 321 (Ont. C.J. (G.D.)), rev'd 93 DTC 5183 (Ont. CA)

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Maritime Telegraph and Telephone Company v. Her Majesty The Queen, 91 DTC 5038, [1991] 1 CTC 28 (FCTD), aff'd 92 DTC 6191 (FCA)

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Tax Topics - Income Tax Act - Section 9 - Accounting Principles 33

Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153, [1989] 1 CTC 363 (FCTD)

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Dixie Lee (Maritimes) Ltd. v. The Queen, 88 DTC 6108 (FCTD), aff'd 91 DTC 5518 (FCA)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) substantial performance of services in 1st year 123

Burrard Yarrows Corp. v. The Queen, 86 DTC 6459, [1986] 2 CTC 313 (FCTD), aff'd sub nomine Versatile Pacific Shipyards Inc. v. The Queen, 88 DTC 6352 (FCA)

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Zoel Chicoine Inc. v. The Queen, 86 DTC 6251, [1985] 2 CTC 320 (FCTD), aff'd 87 DTC 5409, [1987] 2 CTC 240 (FCA)

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Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)

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The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)

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Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 408(1) 48
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) s. 12(1)(a)(i) inapplicable to deposits 49
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) balance of purchase price did not become receivable until condition precedent satisfied 96

Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122 (FCA)

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Commonwealth Construction Co. Ltd. v. The Queen, 82 DTC 6152, [1982] CTC 167 (FCTD), aff'd 84 DTC 6420, [1984] CTC 338 (FCA)

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Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)

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Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Disposition of Property complete divesting of all the benefits and burdens of ownership 59

Oxford Shopping Centres Ltd. v. The Queen, 79 DTC 5458, [1980] CTC 7, aff'd 81 DTC 5065, [1981] CTC 128 (FCA)

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Maple Leaf Mills Ltd. v. Minister of National Revenue, 76 DTC 6182, [1976] CTC 324, [1977] 1 S.C.R. 558

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Harlequin Enterprises Ltd. v. The Queen, 74 DTC 6634, [1974] CTC 838 (FCTD), aff'd 77 DTC 5164, [1977] CTC 208 (FCA)

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Françon Ltée v. MNR, 73 DTC 5514, [1973] CTC 708 (FCA)

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Minister of National Revenue v. Benaby Realties Limited, 67 DTC 5275, [1967] CTC 418, [1968] S.C.R. 12

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) accounts to be left open until determined 154

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 - Nature of Income 134

Minister of National Revenue v. Lechter, 66 DTC 5300, [1966] CTC 434, [1966] S.C.R. 655

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Tax Topics - General Concepts - Effective Date 92

Canadian General Electric Company v. The Minister of National Revenue, 61 DTC 1300, [1961] CTC 512, [1962] S.C.R. 3

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MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) amount is receivable when an absolute, although not necessarily immediate, right to receive 75

Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)

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Minister of National Revenue v. Imperial Oil Co., 60 DTC 1219, [1960] CTC 275, [1960] S.C.R. 735

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MNR v. Publishers Guild of Canada Ltd., 57 DTC 1017, [1957] CTC 1 (Ex Ct)

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Tax Topics - Income Tax Act - Section 9 - Accounting Principles 99

Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433

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Tax Topics - General Concepts - Evidence 32

Ken Steeves Sales Ltd. v. MNR, 55 DTC 1044 (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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Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)

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See Also

Leonard v. The Queen, 2021 TCC 33

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss - Debt loss on mortgage that was acquired in order to acquire the underlying property under foreclosure proceeding on income account was also from an adventure 347
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) Court not bound by an erroneous admission by one of the parties 115
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition foreclosure proceedings resulted in disposition of the mortgage but not of the debt it had previously secured 471
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(i) on a foreclosure, the taxpayer disposed of his mortgage, even though the debt it secured remained outstanding 429
Tax Topics - General Concepts - Evidence Manitoba law, being where the Tax Court hearing was held, was the lex fori governing the mortgage foreclosure proceeding at issue regarding a U.S. property 178

Paletta Estate v. The Queen, 2021 TCC 11

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Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit losses generated under straddles were deducible from a source notwithstanding that they generated small economic losses 261
Tax Topics - General Concepts - Sham FX straddles were not shams, and “window dressing” is not a standalone anti-avoidance doctrine 241
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) a reasonable person would have surfaced the omission of an $8M trading gain with an inquiry of his accountant 391

Mazo v. The Queen, 2016 TCC 232 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business pyramid scheme gives rise to business, not property, income 287
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit pyramid scheme a source of business income 92

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) amount subject to potential repayment obligation was not received 258
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) amounts replaced reduced lease income rather than contributing to leased vehicles' cost 239
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing capital tax accrued from day to day 226
Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income 284
Tax Topics - Income Tax Act - Section 9 - Computation of Profit surcharges received by lessor at lease termination for excess use were income 264

Kruger Incorporated v. The Queen, 2015 DTC 1127 [at 788], 2015 TCC 119, rev'd 2016 FCA 186

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Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) options contracts purchased, but not those written, were inventory 200
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory options contracts purchased, but not those written, were inventory 122
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) paper manufacturer's large-scale options-trading operation was a separate business 166

Malo v. The Queen, 2012 DTC 1214 [at 3588], 2012 TCC 75 (Informal Procedure)

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Reilly v. The Queen, 2010 DTC 1223 [at 3623], 2010 TCC 326

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Langille v. The Queen, 2009 DTC 1431, 2009 TCC 398

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Destacamento v. The Queen, 2009 DTC 806, 2009 TCC 242 (Informal Procedure)

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2187878 Nova Scotia Limited v. The Queen, 2007 DTC 761, 2007 TCC 249

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Ferro v. The Queen, 2003 DTC 491 (TCC)

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Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642

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Iron Ore Co. of Canada v. The Queen, 2000 DTC 1725 (TCC)

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Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)

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R. & J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)

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Fleur de Lys Warehousing Ltd. v. MNR, 91 DTC 1343, [1992] 2 CTC 2158 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 51

Yesac Creative Foods Inc. v. MNR, 91 DTC 413, [1991] 2 CTC 2622 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Compensation Payments 83

Recordwide Distributors, Inc. v. C.I.R., 82-2 U.S.TC 84:713 (C.A. 8)

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Willingale v. International Commercial Bank Ltd. (1978), 52 TC 242 (HL)

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Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)

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Tax Topics - General Concepts - Fair Market Value - Other 60
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) benefit in year of note issuance/tenant improvement benefit based on PV of reversion boost 317

Burley Tobacco Growers Cooperative Association, Inc. v. U.S., 68-2 U.S.TC 87:579 (D.C. Ky.)

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British South Africa Co. v. Varty, [1966] A.C. 381 (HL)

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Automobile Club of N.Y., Inc. v. CIR, 62-2 U.S.TC 85:342 (C.A. 2)

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Elson v. Prices Taylors, Ltd. (1962), 40 TC 671 (Ch. D.)

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Words and Phrases
deposit

Anderson Logging Co. v. The Queen, 52 DTC 1215 (PC)

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Jay's - The Jewellers, Ltd. v. C.I.R. (1947), 29 TC 274 (K.B.D.)

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Cowen's Ideal Trading Stamp Co. (Glasgow) Ltd. v. C.I.R. (1934), 19 TC 154 (C.S. (1st D.))

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Brown v. Helvering, 290 U.S. 193 (1933)

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Administrative Policy

13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Benefit - Paragraph (a) benefit includible in deceased annuitant’s return was not subject to "benefit"-(a) exclusion because it was not reported 312
Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) s. 146(8) benefit paid to the taxpayer’s administrator was not includible in her income until the year she was identified and received the amount 369
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(c) tax imposed on RRSP under s. 146(4)(c) where RRSP issuer unaware of annuitant’s death 187
Tax Topics - General Concepts - Payment & Receipt constructive receipt of amount deducted on account of fees that were the recipient’s obligation 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees incurred as a consequence of receiving unclaimed property (which was taxable under s. 146(8)) were non-deductible 205

4 May 2010 External T.I. 2009-0329391E5 F - Provision pour retour de marchandises

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) no reserve where book publisher’s customers could return unsold books, cf. where a "true" clause for the return of unsold goods 230

21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges hedges re dividend or interest obligations of parent on income account 212

9 October 2015 APFF Roundtable Q. 9, 2015-0595661C6 F - Question 9 - Table Ronde APFF 2015

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) s. 20(1)(m) reserve may be claimable for an amount included under s. 9 rather than 12(1)(a) 167

23 December 2014 External T.I. 2013-0487791E5 F - Période d'amortissement du revenu d'emphytéose

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition sum received on granting an emphyteusis is proceeds of disposition 191

6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) irrevocable royalty prepayment under s. 12(1)(a) or 9 139

10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Boni suite à la signature d'un contrat d'appro

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11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder 113
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder 170
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder 175
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 226
Tax Topics - General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV 134
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 165

2 April 2013 External T.I. 2013-0475571E5 - Life insurance

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22 November 2011 External T.I. 2011-0404021E5 F - Revenu des entrepreneurs

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Words and Phrases
construction

29 August 2011 Internal T.I. 2009-0336671I7 - Derivative

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract interest rate swap not a debt obligation 93

20 March 2012 External T.I. 2011-0424461E5 F - Déduction d'une rétribution à un agent immobilier

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Income Tax Technical News-42, 31 May 2010

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30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale

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Tax Topics - General Concepts - Payment & Receipt amounts paid by set-off are both paid even though no movement of funds 274
Tax Topics - Income Tax Act - Section 248 - Subsection 248(16) - Paragraph 248(16)(a) - Subparagraph 248(16)(a)(i) addition for GST and subtraction for ITC 141

19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures derivative that effectively locked in effective interest rate on proposed bond issuance on income account 115
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) hedging expense to lock in interest rate 105

26 May 2008 Internal T.I. 2008-0272771I7 - Straight-line Amortization or Averaging of Rent

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10 January 2008 External T.I. 2005-0139681E5 F - Dépenses reportées à une année ultérieure

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24 March 2003 Internal T.I. 2003-0184127 - COMMODITY OPTIONS

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1999 Ruling 9903543 - TOTAL RETURN SWAPS & MUTUAL FUND TRUST

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25 March 1999 Internal T.I. 9828577 - PART I.3/RESERVES,ADVANCES&SURPLUS

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3 May 2000 T.I. 1999 - 001391

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23 November 1999 External T.I. 9824405 - TIMING OF LOSS RECOGNITION--FUTURES CONTRACTS

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22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities

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11 April 1990 T.I. AC58705 File 5-8705

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Income Tax Technical News, No. 16, 8 March 1999: Comments on Canderel, College Park and Ikea cases.

Income Tax Technical News, No. 14, "Reporting of Derivative Income by Mutual Funds"

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Income Tax Technical News, No. 8, 30 September 1996, "Proceeds of Sale of a Condominium - First Closing Date or Second Closing Date".

23 July 1996 External T.I. 9615915 - TIMING OF REVENUE RECOGNITION S

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5 December 1995 External T.I. 9516145 - LEASE INDUCEMENTS

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29 March 1995 Internal T.I. 9419557 - FEDERAL SALES TAX REFUND

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Income Tax Technical News, No. 1, 22 July 1994

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19 July 1994 Memorandum (C.T.O. "Mutual Fund Limited Partnerships")

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31 October 1994 External T.I. 9421625 - INCOME RECOGNITION

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25 August 1994 Internal T.I. 9419527 - SHORT-TERM CONTRACTS

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21 June 1994 External T.I. 9414065 - COMPLETION METHOD CONTRACT NOT FINISHED AFTER 2 YEARS

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3 February 1994 External T.I. 5-932925 -

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Halifax Round Table, February 1994, Q. 23

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1994 A.P.F.F. Round Table, Q. 25

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Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.")

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9 January 1993 Memorandum (Tax Window, No. 30, p. 9, ¶2487)

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13 May 1992 Internal T.I. 7-921151 -

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91 C.R. - Q.41

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16 July 1991 T.I. (Tax Window, No. 6, p. 14, ¶1350)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 216 - Subsection 216(1) 49

14 May 1991 T.I. (Tax Window, No. 3, p. 13, ¶1238)

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15 January 1990 Memorandum (June 1990 Access Letter, ¶1287)

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15 January 1990 Memorandum (June 1990 Access Letter, ¶1251)

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89 C.R. - Q.30

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89 C.R. - Q.22

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87 C.R. - Q.25

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85 C.R. - Q.31

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IT-479R, para. 28-32

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IT-92R2 "Income of Contractors"

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Articles

Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36

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Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377

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Harris, "Developments in Asset-backed Financing: Tax Considerations", Business Vehicles, Vol. III, No. 3, 1997, p. 136

Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16

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Allgood, "Eaton's Leads With Public Securitization of Credit Card Receivables", Corporate Finance, Vol. 1, No. 1, 1992, p. 5

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Mandell, Yip, "Tax Shelters in the 1990's", 1991 Conference Report, pp. 35:23-35:28

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Pagan, "Measurement of Commercial Profit for Tax Purposes (Or What Willingale Was Really About)", British Tax Review, 1992, No. 2, p. 75

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Tiley, "More on Receivability and Receipt", 1986 British Tax Review, p. 152.

Tiley, "Receivability and Receipt: The Problem of Timing Under Income Tax Legislation", 1982 British Tax Review, p. 23.

Accounting Pronouncements

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