Words and Phrases - "debt"
Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160
In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...
23 February 2001 External T.I. 2001-0066265 F - Salaire différé français
Before finding that receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to...
17 October 2002 Internal T.I. 2002-0159107 F - SALAIRE PAYE D'AVANCE
The pay system would be changed so that the employees, who currently are paid at the end of each two-week period of work, would instead be paid...
Canada (Attorney General) v 18335898 Alberta Ltd (Whitecap Energy Inc), 2023 ABKB 357
The defendant (“Whitecap Energy”) was an Alberta corporation which had been wound up into its sole shareholder (“Whitecap Resources”) and...
Barejo Holdings ULC v. Canada, 2020 FCA 47
An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...
Moose Factory Restaurant Properties Ltd. v. The Queen, 2019 TCC 156
After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts...
Hokhold v. Canada, 2018 FCA 163
Partly as a delayed consequence of CRA’s seizure of computers and dental equipment of a dental practice and the misplacing of records when his...
Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:
"Liability" v. "debt" (pp. 716-717)
The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...
28 January 2016 External T.I. 2015-0617771E5 F - Bump calculation
Is the balance of the “future income tax liabilities” (being an accounting provision which was not deducted in computing income) presented in...
6 April 1993 T.I. (Tax Window, No. 30, p. 5, ¶2493)
Anderson v. MNR, 92 DTC 2296 (TCC) (in which a letter of the taxpayer's accountant requesting the application of an allowable business investment...
5 November 2013 External T.I. 2013-0501241E5 F - Application of subsection 39(2)
Respecting whether s. 39(2) applied on the payment of a previously declared dividend, CRA stated (TaxInterpretations translation):
A dividend, at...
4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation
As a condition to distributing shares of Aco to the beneficiaries of a testamentary trust of which it was sole trustee, the trustee ("Pubco"),...
24 March 2005 Internal T.I. 2005-0115921I7 - Specified debt obligations & loan originating cost
Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a...
Gibraltar Mines Ltd. v. The Queen, 83 DTC 5294, [1983] CTC 261 (FCA)
The "debt" need not be for the price of merchandise sold or services rendered in the course of business, but may also represent business expenses...
Tonolli Canada Ltd. v. Minister of National Revenue, 91 DTC 520, [1991] 1 CTC 2607 (TCC)
After a venture carried on through a U.S. subsidiary which was owned by the taxpayer and its Netherlands parent proved to be unsuccessful, the...
Delle Donne v. The Queen, 2015 TCC 150
In rejecting a submission that the taxpayer was not entitled to deduct a doubtful debt reserve for unpaid interest because no written demand to...
Barejo Holdings ULC v. The Queen, 2015 DTC 1216 [at at 1405], 2015 TCC 274, aff'd on other grounds 2016 FCA 304
The question referred by the parties pursuant to Rule 58 was whether two contracts, entitled Notes and issued for US $998 million by affiliates of...
Noble v. Lashbrook, 40 DLR 93, [1918] 1 WWR 918 (Sask CA)
After the plaintiff discovered that his sale of a threshing machine to the defendant was legally ineffective, he received an award at trial for...
Guay v. R., 75 DTC 5090, [1975] C.T.C. 150 (FCTD)
At the time of death of the deceased, a director of his family business corporation, he was under investigation by the Department of National...
Walsh Estate v. Minister of Finance (B.C.), [1979] CTC 251, at 257 (BCSC)
The deceased had gone through the form of a marriage in Las Vegas while he had not yet completed his divorce with his first wife, and he soon had...
Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)
The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange...
Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC)
Before finding that payments made by a corporation to its shareholder-employees constituted debts of the employees rather than representing...
Cloutier-Hunt v. The Queen, 2007 DTC 947, 2007 TCC 345 (Informal Procedure)
Interest awarded on a retroactive award of back pay by the Canadian Human Rights Tribunal did not represent interest on a "debt obligation" as...