Words and Phrases - "in relation to"
Potash Corporation of Saskatchewan Inc. v. The Queen, 2022 TCC 75, aff'd 2024 FCA 35
The taxpayer, which produced and sold potash from mines in Saskatchewan, was subject to both a profit tax and to the making of “base payments”...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | deductibility of Saskatchewan potash tax “base payments” denied given that sales they were applied to were a proxy for income | 357 |
Westcoast Energy Inc. v. Canada, 2022 FCA 57
Westcoast reimbursed (through Manulife as its agent) employees who had incurred various health care services – including some which were...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 170 - Subsection 170(1)) - Paragraph 170(1)(b) - Subparagraph 170(1)(b)(ii) | s. 170(1)(b)(ii) did not apply to reimbursed employee health care services as the services were acquired by the employees rather than the employer | 201 |
Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151
The members of the Appellant (which was a non-share Delaware corporation resident in Canada) included Canadian and U.S.-resident individuals who...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | annual fees charged by non-share corporation to its members were not reimbursements for expenses incurred by it as their agent | 377 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service | payment of condo operating expenses was a service | 211 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | single supply of covering all time share operating costs | 172 |
| Tax Topics - Excise Tax Act - Section 168 - Subsection 168(1) | GST collectible based on invoicing times | 79 |
| Tax Topics - Excise Tax Act - Section 306.1 - Subsection 306.1(1) | objecting to quantum was sufficient particularity | 177 |
| Tax Topics - General Concepts - Ownership | beneficial owner did not transfer property risk | 183 |
| Tax Topics - General Concepts - Evidence | foreign law assumed the same | 101 |
Miedzi Copper Corporation v. The Queen, 2015 TCC 26 (Informal Procedure)
Essentially the appellant's only activity was to indirectly finance the mineral exploration activities of six Polish subsidiaries of its immediate...
ExxonMobil Canada Ltd. v. Canada, 2010 FCA 1
The appellants were required to relocate their employees to different locations as part of their business. In addition to reimbursing direct...
Stantec Inc. v. The Queen, 2008 TCC 400 (Informal Procedure), aff'd 2009 FCA 285
The appellant acquired a US public company ("Keith") in a Delaware merger (in which Keith Industries merged into the appellant's US subsidiary,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 186 - Subsection 186(1) | listing fees to issue shares to target shareholders were eligible | 263 |
GST/HST memorandum 9.4 "Reimbursements" June 2012
15. However, if a person is an employee, a partner or a volunteer at the time the property or service is acquired, imported or brought into a...
12 December 2012 Interpretation Case No. 142112
A real estate broker based in Nova Scotia is hired by a company with a head office in Nova Scotia to lease real property in New Brunswick to a...