Words and Phrases - "gift"

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1 February 2023 External T.I. 2022-0945221E5 - Directed gift to a municipality

Summary Under
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Disbursement
a directed gift is not a gift

Regarding the receipt of funds by a qualified donee that is a municipality from a registered charity where such funds would then be directed to a...

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Words and Phrases
gift

6 April 2003 External T.I. 2003-0054461E5 F - Traitement fiscal d'un cadeau

Summary Under
Tax Topics - Income Tax Act - Section 9 - Nature of Income
“gift” may be business income to the recipient

In indicating that an amount described as a “gift” could be business income to the recipient, CRA stated:

…IT-334R2[, para. 4] … states...

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Words and Phrases
gift

24 January 2019 External T.I. 2018-0773301E5 - Paragraph 69(1)(c) and Nominal Consideration

Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
a transfer structured as a sales agreement for nominal consideration may qualify as a gift

$1 consideration is specified in the legal documentation for a gift of property by a parent to a child solely to ensure the agreement is legally...

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Words and Phrases
gift

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 FCA 36

Summary Under
Tax Topics - Income Tax Act - Section 110.1 - Subsection 110.1(1) - Paragraph 110.1(1)(a)
consideration for "gift" was elimination of obligation to invest the funds

The appellant was the limited partner of a partnership (“SEC”) that had become insolvent during efforts to relaunch a paper mill close to the...

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Words and Phrases
gift

Cassan v. The Queen, 2017 TCC 174

Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
gratuitous transfer is gift irresepctive of absence of benevolent intent

In rejecting (at para. 296) a Crown submission (summarized at para. 249) that “gift” required “detached and disinterested generosity”)...

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Words and Phrases
gift

S7-F1-C1 - Split-receipting and Deemed Fair Market Value

Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts

Meaning of "gift"

1.2 Under the common law, “a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no...

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Words and Phrases
gift

French v. Canada, 2016 FCA 64

Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts
Parliament may have intended what constitutes a gift outside Quebec to be partly informed by the Civil Code

In his 2000 to 2002 taxation years, the taxpayer made gifts to a registered charity that were funded from personal funds and from loans tied to...

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Words and Phrases
gift

26 June 2013 External T.I. 2013-0490711E5 F - Disposition en contrepartie de 1$

Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c)
nature of Quebec gift

Could the acquisition of a property for consideration of one dollar qualify as an acquisition by gift for purposes of s. 69(1)(c)? The Directorate...

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Words and Phrases
gift

16 April 2013 External T.I. 2013-0477981E5 F - Interpretation of Gift

Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts
ability to opt out of a compulsory contribution to an employer-aligned charity would not necessarily establish a “gift”/Quebec “gift” is CCQ “donation”

A Quebec collective agreement requires each employee to annually pay a specified amount to a pre-established registered charity whose mission...

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Words and Phrases
gift don

Berry v. Warnett, [1980] T.R. 299 (C.A.), rev'd [1980] BTC 239 (HL)

Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b)

"[T]he ordinary primary meaning of 'gift' is a voluntary transfer of property made without consideration."

Words and Phrases
gift

The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b)

A sale by the taxpayer to his sons of shares for their market price at a time when the taxpayer had insider knowledge that an offer would be made...

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Words and Phrases
gift