Cases
Kruger Incorporated v. Canada, 2016 FCA 186
The taxpayer traded foreign currency options as a separate business from its pulp and paper business, with its principal option activity being the...
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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)
The taxpayer, a real estate developer, prepaid municipal real estate development charges applicable to one of its residential lots developments....
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 58 |
Canada v. Canada Safeway Limited, 98 DTC 6060, [1998] 1 CTC 120 (FCA)
The Queen v. Johnson and Johnson Inc., 94 DTC 6125 was followed in finding that a refund of federal sales previously paid in error did not...
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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
Given that the trial judge had made a finding that the primary purpose of the taxpayer in making two payments to or for the benefit of two tenants...
Ikea Ltd. v. R., 98 DTC 6092, [1998] 1 S.C.R. 196, [1998] 2 C.T.C. 61
Because there were no conditions attached to the use by the taxpayer of a tenant inducement payment (the sole condition precedent to receipt of...
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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. R., 98 DTC 6100, [1998] 1 S.C.R. 147, [1998] 2 C.T.C. 35
The taxpayer, which had entered into an agreement with a property owner to develop the property as a commercial office development, paid just over...
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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)
A federal sales tax refund was not receivable by the taxpayer until the Minister had given some public and irrevocable indication thereof....
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 54 | |
| Tax Topics - Statutory Interpretation - Certainty | 94 |
Friedberg v. Canada, 93 DTC 5507, [1993] 4 S.C.R. 285, [1993] 2 CTC 306
The taxpayer, who was the general partner of a firm of commodity brokers, entered into spread positions in gold futures contracts, and in the same...
West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023, [1992] 1 CTC 15 (FCA)
Hydro-Electric Utility included in its income for financial statement purposes an estimate of the value of electricity which had been consumed by...
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 194 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 115 |
R. v. Fogazzi, 92 DTC 6421, [1992] 2 CTC 321 (Ont. C.J. (G.D.)), rev'd 93 DTC 5183 (Ont. CA)
If the accused had been taxable on amounts misappropriated by him (which was not the case), he would have been taxable in the year the money was...
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| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 97 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 81 | |
| Tax Topics - Income Tax Act - Section 3 | 109 |
Maritime Telegraph and Telephone Company v. Her Majesty The Queen, 91 DTC 5038, [1991] 1 CTC 28 (FCTD), aff'd 92 DTC 6191 (FCA)
The taxpayer, which billed its clients for local and long distance charges on a monthly basis, and which prior to 1984 had included in its income...
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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)
The taxpayer was not permitted to exclude from its income from a pipeline the portion of the tariffs charged by it to shippers which was in excess...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 83 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve for revenues collected at excess rate | 98 |
Dixie Lee (Maritimes) Ltd. v. The Queen, 88 DTC 6108, [1988] 1 CTC 193 (FCTD), aff'd 91 DTC 5518 (FCA)
In consideration of the payment to the taxpayer of franchise fees the taxpayer granted to the franchisee the right to use the taxpayer's name and...
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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)
The taxpayer, upon completing each of the various stages of construction of ships, became absolutely entitled to receive progress payments. The...
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 64 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve if s. 9 inclusion | 25 |
Zoel Chicoine Inc. v. The Queen, 86 DTC 6251, [1985] 2 CTC 320 (FCTD), aff'd 87 DTC 5409, [1987] 2 CTC 240 (FCA)
The taxpayer was entitled to receive a management fee equal to 10% of the net profits from a shopping centre including gains from its sale. Since...
Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)
It was stated by Muldoon, J. that under the scheme of the Act, taxable income is determined on an annual basis, as opposed to being determined...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(m) | 87 |
The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 40 (FCA)
A submission was accepted that a property is sold when (1) the beneficial ownership has passed under a binding agreement of purchase and sale, and...
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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, 84 DTC 6126 (FCA)
The costs of inventory should be deducted from income in the year of sale. To deduct such costs during a prior year in which such costs were...
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| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | landscaping an addition to inventory cost | 53 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(aa) | inventory costs not included | 321 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 52 | |
| Tax Topics - Statutory Interpretation - Scheme | 67 |
Commonwealth Construction Co. Ltd. v. The Queen, 82 DTC 6152, [1982] CTC 167 (FCTD), aff'd 84 DTC 6420, [1984] CTC 338 (FCA)
Amounts received by the taxpayer pursuant to judgment in a mechanics' lien action were ascertained amounts, and income in the years of receipt,...
Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)
Inclusion of uncertified progress claims in a construction company's income (as opposed to deferring recognition to the year of certification) was...
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| Tax Topics - General Concepts - Estoppel | 48 | |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 66 |
Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)
A sale of apartments by the taxpayer was held to occur under the laws of Quebec at the time of execution and delivery of the deed of sale rather...
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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)
"[F]or income tax purposes, while the 'matching principle' will apply to expenses related to particular items of income, and in particular with...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | perimeter road construction for promotion | 138 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Marketing Expenditures | 138 |
Maple Leaf Mills Ltd. v. Minister of National Revenue, 76 DTC 6182, [1976] CTC 324, [1977] 1 S.C.R. 558
The taxpayer, upon its purchase of an oil tanker, received a secured revenue guarantee from the vendors. The amounts of the revenue deficiencies...
Harlequin Enterprises Ltd. v. The Queen, 74 DTC 6634, [1974] CTC 838 (FCTD), aff'd 77 DTC 5164, [1977] CTC 208 (FCA)
The taxpayer was obliged to accept the return of paperbacks previously shipped by it which remained unsold, and it deducted in computing its...
Françon Ltée v. MNR, 73 DTC 5514, [1973] CTC 708 (FCA)
In order to obtain an immediate release of construction holdbacks from the customers of its construction business, the taxpayer deposited...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense | 90 |
Minister of National Revenue v. Benaby Realties Limited, 67 DTC 5275, [1967] CTC 418, [1968] S.C.R. 12
In finding that the taxpayer realized income from land inventory in its 1955 taxation year (when an agreement was reached with the Crown fixing...
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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
In order to secure a regular supply of rebuildable engines, when the taxpayer sold engines which it had rebuilt to Ford dealers it required the...
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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
In the taxpayer's 1955 taxation year, he accepted the Department of Transport's formal offer of settlement for compensation in respect of its...
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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
In 1950, 1951 and early 1952, the taxpayer purchased supplies from its U.S. parents and gave promissory notes evidencing the U.S.-dollar amounts...
MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)
A contractor was required to recognize income from contracts for the installation of heating and plumbing systems as the progress payments became...
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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)
The taxpayer, which followed the "completed contract" method of recognizing income on long-term contracts for the excavation of sewers and water...
Minister of National Revenue v. Imperial Oil Co., 60 DTC 1219, [1960] CTC 275, [1960] S.C.R. 735
In computing its "profits ... reasonably attributable to the production of oil or gas", the taxpayer treated oil delivered by its producing...
MNR v. Publishers Guild of Canada Ltd., 57 DTC 1017, [1957] CTC 1 (Ex Ct)
The taxpayer, whose business was the selling of books and magazines through door-to-door canvassers, was found by Thorson P. to be entitled to...
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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
The taxpayer was found to have made deliveries of periodicals to its retail dealers on a sale or return basis, with the result that the sale price...
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| Tax Topics - General Concepts - Evidence | 32 |
Ken Steeves Sales Ltd. v. MNR, 55 DTC 1044, [1955] CTC 47 (Ex Ct)
The taxpayer, which in the first year of its operations deducted expenses on an accrual basis but excluded from its income sales that were...
Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82
Taxi owners contracted with the taxpayer to pay the taxpayer $500 per taxi for the privilege of operating their taxis within the taxpayer's...
Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)
The taxpayer, which acted as agent for underwriting members of Lloyd's of London in the writing of workman's compensation, employer's liability...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 114 |
See Also
Leonard v. The Queen, 2021 TCC 33, rev'd 2022 FCA 195
In finding that the taxpayer could not deduct his cost of purchasing distressed mortgage debt as an adventure in the nature of trade, Sommerfeldt...
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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, rev'd 2022 FCA 86
In order that he could shelter most or all of his income for his 2000 to 2006 taxation years through a straddle program (with much of his 2007...
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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)
The taxpayer (Ms. Mazo) participated in and profited on balance from a pyramid scheme, which in form entailed the participants paying the promoter...
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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
General Motors of Canada Limited ("GMC") made "residual value support payments" to the taxpayer ("GMAC"), which purchased vehicles subject to...
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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
The taxpayer traded foreign currency options as a separate business from its pulp and paper business, with its principal option activity being the...
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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)
After finding that the taxpayer's losses from his stake in a tree-planting operation could not be deducted by virtue of failing to comply with the...
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| Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter | 125 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 102 | |
| Tax Topics - Income Tax Act - Section 3 | 159 |
Reilly v. The Queen, 2010 DTC 1223 [at 3623], 2010 TCC 326
The taxpayer took the position that he engaged in an unsuccessful campaign in 1999 to become mayor of Delta, B.C. in order to enhance his...
Langille v. The Queen, 2009 DTC 1431, 2009 TCC 398
Commissions in respect of policies issued before the taxpayer incorporated a corporation to which he transferred his insurance brokerage business,...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 89 |
Destacamento v. The Queen, 2009 DTC 806, 2009 TCC 242 (Informal Procedure)
The taxpayers, who were life insurance salesmen, received advance commissions when they sold a policy but with a requirement to pay back a portion...
2187878 Nova Scotia Limited v. The Queen, 2007 DTC 761, 2007 TCC 249
The portion of a large write-down that the taxpayer was able to verify as representing overstatements of income or understatements of expenses...
Ferro v. The Queen, 2003 DTC 491 (TCC)
The taxpayer, a litigation lawyer who entered into contingency fee arrangements with all his clients under which he was only entitled to render an...
Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642
A dividend was income to the taxpayer in the year the dividend was declared in light of the "underlying assumption in the Income Tax Act that...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 49 |
Iron Ore Co. of Canada v. The Queen, 2000 DTC 1725 (TCC)
Lamarre Proulx TCJ. found that Canada Safeway Ltd. v. The Queen, 98 DTC 6060 (FCA) was "modified" by Ikea Ltd. v. The Queen, [1998] 1 S.C.R. 196...
Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)
The taxpayer, which operated an airline, was effectively compelled to pay for the major overhaul of each jet engine after every 17,000 hours of...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 77 |
R. & J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)
The taxpayer was unsuccessful in deferring the recognition of income under contracts relating to the installation of manufacturing equipment to...
Fleur de Lys Warehousing Ltd. v. MNR, 91 DTC 1343, [1992] 2 CTC 2158 (TCC)
A refund of municipal taxes constituted income to the taxpayer at the time it received a favourable decision of the tribunal to which it had...
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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)
Lease inducement payments, which the taxpayer received on income account, were required to be included in full in the year of receipt rather than...
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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)
The Court upheld the finding of the Tax Court that the taxpayer "dealt with its customers on a 'sale or returns' basis, and that the right to...
Willingale v. International Commercial Bank Ltd. (1978), 52 TC 242 (HL)
A regular part of a bank's business consisted of discounting or purchasing bills or notes. For accounting purposes the discounts were brought into...
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| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 94 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 40 |
Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)
In contrasting the determination of income under s. 8(1) (now s. 15(1)) and s. 9, Jackett C.J. stated:
"In the case of 'income', it is assumed, in...
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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.)
A farmer's tobacco cooperative organization required each grower who presented tobacco at its warehouse to make an annual contribution, which was...
British South Africa Co. v. Varty, [1966] A.C. 381 (HL)
The taxpayer lent £200,000 to a gold mining company and received, at the time of making the loan, an option to subscribe for shares of the mining...
Automobile Club of N.Y., Inc. v. CIR, 62-2 U.S.TC 85:342 (C.A. 2)
The taxpayer, which was a membership corporation functioning as an automobile club, sold savings plan coupons at face value to participating...
Elson v. Prices Taylors, Ltd. (1962), 40 TC 671 (Ch. D.)
When a customer of the taxpayer ordered a "made-to-measure" suit he was asked for a deposit (although the receipt given to him showed only the...
Anderson Logging Co. v. The Queen, 52 DTC 1215 (PC)
The taxpayer sold timber limits for minimum guaranteed payments of $180,000 of which $80,000 was paid on the date of the contract, $50,000 (or...
Jay's - The Jewellers, Ltd. v. C.I.R. (1947), 29 TC 274 (K.B.D.)
Where the taxpayer, which carried on a pawnbroker business, sold an unredeemed pledge for an amount between 10s. and £10, the surplus of the...
Cowen's Ideal Trading Stamp Co. (Glasgow) Ltd. v. C.I.R. (1934), 19 TC 154 (C.S. (1st D.))
The taxpayer "sold" books of stamps to shopkeepers who distributed the stamps free of charge to retail customers in proportion to the value of...
Brown v. Helvering, 290 U.S. 193 (1933)
The full amount of the gross overriding commissions on business written by a fire insurance agent in a year were included in his income and he was...
Administrative Policy
7 June 2022 External T.I. 2019-0796641E5 - Stock options issued to a corporation
A Canadian-controlled private corporation (“CCPC”) is granted an option to acquire shares of an arm’s length CCPC. The option will only vest...
13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits
The estate of the deceased annuitant of an RRSP was fully settled without the executor (his surviving wife and the sole beneficiary) being aware...
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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 | 377 |
| 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
Where a book publisher’s customers could return unsold books, it could not deduct a reserve from the profit required to be recognized by it on...
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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
Canco, which was wholly-owned by its Canadian Parent, entered into “Dividend Bond Locks” and “Interest Bond Locks” (collectively, the...
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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
In order to enhance customer retention, a manufacturer agrees with its independent distributors to disburse $1,000,000 to them over two years if...
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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
A corporation rents a property under an emphyteutic lease for a lump sum. Is it able to amortize that amount over the period stipulated in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
Corporation G and Corporation D, who were affiliated corporations, were the licensor and licensee of a licence to manufacture and sell a product...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The purchaser under a major supply agreement negotiated a "signing bonus" of $5 million (payable equally in the first and second year) in...
11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
Publico determined to grant stock options to its directors and consultants, as a result of which a private corporation ("Corporation"), that had...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
In accordance with Destacamento and Demeterio, CRA found several bases on which a self-employed taxpayer's life insurance sales commissions must...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 140 | |
| Tax Topics - Income Tax Act - Section 32 - Subsection 32(1) - Paragraph 32(1)(a) | 140 |
22 November 2011 External T.I. 2011-0404021E5 F - Revenu des entrepreneurs
CRA takes the position that renovation of buildings or work on water supply and sewage systems is not a "construction activity" under IT-92R2,...
29 August 2011 Internal T.I. 2009-0336671I7 - Derivative
Interest rate swap transactions were entered into between a controlled foreign affiliate of the taxpayer ("BCo") and a foreign financial...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
A taxpayer who owns two properties that allow the earning of rental income, and pays a real estate agent commissions (based on a percentage of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | lease-up commissions were current expenses | 120 |
Income Tax Technical News-42, 31 May 2010
"For tax purposes, the realization principle is generally the rule of law."
30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale
All the condo owners in a condo complex that was used only in a high-end commercial accommodation business leased their units to a manager for a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
Under a "gilt lock" hedge, the taxpayer, between the time of deciding to issue the bonds and the time of actually issuing them would hedge against...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The smoothing of rent expenses generally required by GAAP is not permitted in computing income for tax purposes.
10 January 2008 External T.I. 2005-0139681E5 F - Dépenses reportées à une année ultérieure
In response to a query regarding a client's ability to deduct expenses in a taxation year subsequent to the one in which they were incurred, CRA...
6 December 2006 External T.I. 2005-0163291E5 F - Résiliation d'une entente contractuelle
A corporation terminated a contractual services agreement and paid compensation to the other party equivalent to the present value of the amounts...
29 June 2006 External T.I. 2006-0169231E5 F - Revenu de location
A taxpayer was required under GAAP to level out the rental payments receivable by it under an operating lease so that the rental income accrued to...
7 June 2005 External T.I. 2005-0121921E5 F - Paiement à un emphytéote
Regarding a payment made by a landowner to a related corporation as an inducement to enter into a contract granting a right of emphyteusis, CRA...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | Belgega -finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure - noted | 122 |
26 April 2005 External T.I. 2004-0107761E5 F - Aide à domicile/SAAQ
A taxpayer, injured in an automobile accident in 1994, received in 2004 a sum from the Quebec auto insurer (the “SAAQ”) to reimburse him for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | Maurice inapplicable where the adult, mentally capable, victim receives the insurance himself and pays it as compensation for his wife’s care services | 237 |
9 January 2004 External T.I. 2003-0049195 F - Winding Up or a Contractor Subco
Opco, which is wholly-owned by Holdco, and has been using the percentage-of-completion method in computing its income from its construction...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(e.1) | s. 88(1)(e.1) would permit parent to step into shoes of sub re s. 12(1)(a) inclusion and s. 20(1)(m) reserve | 161 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | deferred revenue of construction contractor would not be triggered on its s. 88(1) wind-up and parent would be put to claiming any available new s. 20(1)(m) reserve | 161 |
24 March 2003 Internal T.I. 2003-0184127 - COMMODITY OPTIONS
"Where [commodity] options that are sold are on income account and the taxpayer is not a mutual fund trust (where the mark-to-market approach is...
1999 Ruling 9903543 - TOTAL RETURN SWAPS & MUTUAL FUND TRUST
An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18.1 - Subsection 18.1(15) | 148 |
25 March 1999 Internal T.I. 9828577 - PART I.3/RESERVES,ADVANCES&SURPLUS
upfront fees received on interest/currency swaps likely were includible in income under s. 9 (so that no reserve under s. 20(1)(m) was available)...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 49 |
3 May 2000 T.I. 1999 - 001391
Where a stock option is granted to a business supplier, the fair market value of the option will be included in the supplier's income at the time...
23 November 1999 External T.I. 9824405 - TIMING OF LOSS RECOGNITION--FUTURES CONTRACTS
At different times in year 1, a speculator entered into two separate futures contract, each with an arm's length third party. Under the first...
22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities
The correspondent noted that under the GAAP that prevailed in 2008 (contained in Section 3855 of the CICA Handbook) taxpayers whose financial...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 138 | |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | financial liabilities not to be marked to market | 138 |
11 April 1990 T.I. AC58705 File 5-8705
premiums received for the issue of bonds (presumably on income account) were to be included in income at the time of issue under s. 9 rather than...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 124 |
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"
RC will accept (at the choice of the mutual fund) either the realization method or the mark-to-market method for recognizing income on futures,...
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
In the business of providing services with respect to property of another person, revenue is recognized when the fee for the service is billed or...
5 December 1995 External T.I. 9516145 - LEASE INDUCEMENTS
"Where a rental agreement provides for a rent-free period and there is no legal obligation on the part of the tenant to pay rent in respect of...
29 March 1995 Internal T.I. 9419557 - FEDERAL SALES TAX REFUND
A federal sales tax refund that is received in respect of a prior year is to be included in income in the year of receipt rather than in the prior...
Income Tax Technical News, No. 1, 22 July 1994
Beginning July 1995, sales commission expenses incurred by limited partnerships in connection with the distribution of mutual funds must be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii) | taxable co-owner permitted | 31 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 65 |
19 July 1994 Memorandum (C.T.O. "Mutual Fund Limited Partnerships")
RC distinguishes mutual fund management corporations from limited partnerships and accepts that the former are allowed to deduct sales commission...
31 October 1994 External T.I. 9421625 - INCOME RECOGNITION
Re whether a taxpayer that manufactures on a made-to-order basis and that, for accounting purposes, recognizes a percentage of income as each...
25 August 1994 Internal T.I. 9419527 - SHORT-TERM CONTRACTS
A contractor that has entered into contacts that are to be completed within two years of the date of commencement and that comprise various...
21 June 1994 External T.I. 9414065 - COMPLETION METHOD CONTRACT NOT FINISHED AFTER 2 YEARS
Generally, where a contractor reasonably has estimated that a contract will be completed within 24 months from its commencement, but due to...
3 February 1994 External T.I. 5-932925
It is RC's understanding that the issuer of mortgage-backed securities administers the pooled mortgages and is entitled as payment for services to...
Halifax Round Table, February 1994, Q. 23
Where a taxpayer accrues in its financial statements at year end a portion of an invoice which is not released until after the year end, it may be...
1994 A.P.F.F. Round Table, Q. 25
A conditional sale of property to a client could be included in computing income under s. 9(1).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 44 |
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.")
RC will permit a film limited partnership to report its revenue (including revenue subject to a revenue guarantee) on a cash basis (on the...
9 January 1993 Memorandum (Tax Window, No. 30, p. 9, ¶2487)
Liquidated damages to be paid over a period of three to four years to a corporation for termination of a management agreement would be included in...
13 May 1992 Internal T.I. 7-921151
Gold loans of gold producers should be revalued annually at the close of the borrower's tax year, with the resulting gain or loss included in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | 21 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | gold loans of producers | 19 |
91 C.R. - Q.41
The date of disposition of property (and, therefore, the date upon which income commences to be earned by the purchaser) is the date the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | 49 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 35 |
16 July 1991 T.I. (Tax Window, No. 6, p. 14, ¶1350)
Where a non-resident trust which has made the election under s. 216(1) receives a lump sum as payment of the entire three-year rent for Canadian...
| 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)
Where a construction contract originally is for less than two years, so that the completion method of revenue recognition is available, but a...
15 January 1990 Memorandum (June 1990 Access Letter, ¶1287)
The accounting practices expressed by CIPREC respecting rent-free periods granted by lessors as inducements should be followed.
15 January 1990 Memorandum (June 1990 Access Letter, ¶1251)
Discussion of the tax consequences of a short sale occurring under the laws of Quebec.
89 C.R. - Q.30
RC is appealing the decision in Friedberg and is not reconsidering its position with respect to commodities straddle transactions.
89 C.R. - Q.22
The liability of a borrower of gold in the business of mining and selling gold should be valued at the borrower's year-end and any gain or loss...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 45 |
87 C.R. - Q.25
Condominium developers are required, in accordance with GAAP, to recognize their profit at the time of the first closing (occupation by the...
85 C.R. - Q.31
The matching principle is mandatory subject to any contrary provision of the Act.
IT-479R, para. 28-32
Discussion of timing of recognition of gains and losses on exchange traded call and put options.
Para. 25: Gains or losses of a writer of naked...
IT-92R2 "Income of Contractors"
Discussion of recognition of holdbacks and discussion of "completion method".
Articles
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36
Timing of employer loss recognition on hedge of phantom unit obligations (pp. 13:9-10)
Corporate employers may create phantom stock plans and...
Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377
Discussion of the realization principle.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 5 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 5 |
Harris, "Developments in Asset-backed Financing: Tax Considerations", Business Vehicles, Vol. III, No. 3, 1997, p. 136
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) | 14 | |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 34 |
Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16
Critique of Revenue Canada's position on the distinction between the sale of receivables, and loan secured with receivables.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) | 11 | |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b) | 15 |
Allgood, "Eaton's Leads With Public Securitization of Credit Card Receivables", Corporate Finance, Vol. 1, No. 1, 1992, p. 5
The residual purchase price payment made by the receivables trust to the vendors is accounted for by the selling corporations as proceeds only...
Mandell, Yip, "Tax Shelters in the 1990's", 1991 Conference Report, pp. 35:23-35:28
Discussion of when a film distributor is required to recognize income in respect of advances received from licensees.
Pagan, "Measurement of Commercial Profit for Tax Purposes (Or What Willingale Was Really About)", British Tax Review, 1992, No. 2, p. 75
"There is a body of opinion that Willingale was wrongly decided ..." (p. 80).
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
CICA Emerging Issues Committee, EIC-65, 16 October 1995 "Law Firms - Revenue Recognition":
A law firm should recognize its fee revenue as it...