Cases
Kruger Incorporated v. Canada, 2016 FCA 186
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 56 |
Canada v. Canada Safeway Limited, 98 DTC 6060 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Ikea Ltd. v. Canada, 98 DTC 6092, [1998] 1 S.C.R. 196
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 52 | |
| Tax Topics - Statutory Interpretation - Certainty | 86 |
Friedberg v. Canada, 93 DTC 5507, [1993] 4 S.C.R. 285
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
West Kootenay Power and Light Co. Ltd. v. The Queen, 92 DTC 6023 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 188 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 109 |
R. v. Fogazzi, 92 DTC 6421 (Ont. C.J. (G.D.)), rev'd 93 DTC 5183 (Ont. CA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 89 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 75 | |
| Tax Topics - Income Tax Act - Section 3 | 103 |
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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 33 |
Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 77 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve for revenues collected at excess rate | 96 |
Dixie Lee (Maritimes) Ltd. v. The Queen, 88 DTC 6108 (FCTD), aff'd 91 DTC 5518 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | substantial performance of services in 1st year | 121 |
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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 62 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve if s. 9 inclusion | 23 |
Zoel Chicoine Inc. v. The Queen, 86 DTC 6251, [1985] 2 CTC 320 (FCTD), aff'd 87 DTC 5409, [1987] 2 CTC 240 (FCA)
Gibralter Mines Ltd. v. The Queen, 85 DTC 5085, [1985] 1 CTC 116 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(m) | 85 |
The Queen v. Imperial General Properties Ltd., 85 DTC 5045, [1985] 1 CTC 39 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Rules - Rule 408(1) | 46 | |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) | s. 12(1)(a)(i) inapplicable to deposits | 47 |
| 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 | 92 |
Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | landscaping an addition to inventory cost | 51 |
| 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 | 46 | |
| Tax Topics - Statutory Interpretation - Scheme | 61 |
Commonwealth Construction Co. Ltd. v. The Queen, 82 DTC 6152, [1982] CTC 167 (FCTD), aff'd 84 DTC 6420, [1984] CTC 338 (FCA)
Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | 46 | |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 58 |
Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Disposition of Property | 57 |
Oxford Shopping Centres Ltd. v. The Queen, 79 DTC 5458, [1980] CTC 7, aff'd 81 DTC 5065, [1981] CTC 128 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 | perimeter road construction for promotion | 136 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Marketing Expenditures | 136 |
Maple Leaf Mills Ltd. v. Minister of National Revenue, 76 DTC 6182, [1976] CTC 324, [1977] 1 S.C.R. 558
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Harlequin Enterprises Ltd. v. The Queen, 74 DTC 6634, [1974] CTC 838 (FCTD), aff'd 77 DTC 5164, [1977] CTC 208 (FCA)
Françon Ltée v. MNR, 73 DTC 5514, [1973] CTC 708 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense | 86 |
Minister of National Revenue v. Benaby Realties Limited, 67 DTC 5275, [1967] CTC 418, [1968] S.C.R. 12
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | 73 |
Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)
Minister of National Revenue v. Imperial Oil Co., 60 DTC 1219, [1960] CTC 275, [1960] S.C.R. 735
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
MNR v. Publishers Guild of Canada Ltd., 57 DTC 1017, [1957] CTC 1 (Ex Ct)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 93 |
Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 32 |
Ken Steeves Sales Ltd. v. MNR, 55 DTC 1044 (Ex Ct)
Dominion Taxicab Association v. Minister of National Revenue, 54 DTC 1020, [1954] CTC 34, [1954] S.C.R. 82
Robertson Ltd. v. MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 106 |
See Also
Paletta Estate v. The Queen, 2021 TCC 11
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
Langille v. The Queen, 2009 DTC 1431, 2009 TCC 398
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
2187878 Nova Scotia Limited v. The Queen, 2007 DTC 761, 2007 TCC 249
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Ferro v. The Queen, 2003 DTC 491 (TCC)
Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 49 |
Iron Ore Co. of Canada v. The Queen, 2000 DTC 1725 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Johnston v. Britannia Airways Ltd., [1994] BTC 298 (Ch. D.)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 75 |
R. & J. Engineering Corp. v. MNR, 92 DTC 1844 (TCC)
Fleur de Lys Warehousing Ltd. v. MNR, 91 DTC 1343 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 49 |
Yesac Creative Foods Inc. v. MNR, 91 DTC 413 (TCC)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | 81 |
Recordwide Distributors, Inc. v. C.I.R., 82-2 U.S.TC 84:713 (C.A. 8)
Willingale v. International Commercial Bank Ltd. (1978), 52 TC 242 (HL)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 88 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 36 |
Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Other | 56 | |
| 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 | 305 |
Burley Tobacco Growers Cooperative Association, Inc. v. U.S., 68-2 U.S.TC 87:579 (D.C. Ky.)
British South Africa Co. v. Varty, [1966] A.C. 381 (HL)
Automobile Club of N.Y., Inc. v. CIR, 62-2 U.S.TC 85:342 (C.A. 2)
Elson v. Prices Taylors, Ltd. (1962), 40 TC 671 (Ch. D.)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
depositAnderson Logging Co. v. The Queen, 52 DTC 1215 (PC)
Jay's - The Jewellers, Ltd. v. C.I.R. (1947), 29 TC 274 (K.B.D.)
Cowen's Ideal Trading Stamp Co. (Glasgow) Ltd. v. C.I.R. (1934), 19 TC 154 (C.S. (1st D.))
Administrative Policy
13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 | 141 |
10 October 2014 APFF Roundtable Q. 13, 2014-0538111C6 F - Boni suite à la signature d'un contrat d'appro
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
construction29 August 2011 Internal T.I. 2009-0336671I7 - Derivative
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
24 March 2003 Internal T.I. 2003-0184127 - COMMODITY OPTIONS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
1999 Ruling 9903543 - TOTAL RETURN SWAPS & MUTUAL FUND TRUST
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
23 November 1999 External T.I. 9824405 - TIMING OF LOSS RECOGNITION--FUTURES CONTRACTS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
22 February 2012 External T.I. 2008-0289021E5 - Fair Value Accounting - Liabilities
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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"
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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
5 December 1995 External T.I. 9516145 - LEASE INDUCEMENTS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
29 March 1995 Internal T.I. 9419557 - FEDERAL SALES TAX REFUND
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Income Tax Technical News, No. 1, 22 July 1994
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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")
31 October 1994 External T.I. 9421625 - INCOME RECOGNITION
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
25 August 1994 Internal T.I. 9419527 - SHORT-TERM CONTRACTS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
21 June 1994 External T.I. 9414065 - COMPLETION METHOD CONTRACT NOT FINISHED AFTER 2 YEARS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
3 February 1994 External T.I. 5-932925 -
Halifax Round Table, February 1994, Q. 23
1994 A.P.F.F. Round Table, Q. 25
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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.")
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
9 January 1993 Memorandum (Tax Window, No. 30, p. 9, ¶2487)
13 May 1992 Internal T.I. 7-921151 -
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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)
15 January 1990 Memorandum (June 1990 Access Letter, ¶1287)
15 January 1990 Memorandum (June 1990 Access Letter, ¶1251)
89 C.R. - Q.30
89 C.R. - Q.22
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) | 45 |
87 C.R. - Q.25
85 C.R. - Q.31
IT-479R, para. 28-32
Articles
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36
Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 |