In 1980, Nortel had established a health and welfare trust (the “HWT”) for its employees. Following its insolvency and filing under the CCAA...
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|Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 89 - Subsection 89(1) - Paragraph 89(1)(a)||trust return not admitted at trial opening where no previous notice and not relied upon by CRA||229|
|Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)||a distribution from a health and welfare trust to compensate for lost insurance coverage was not a taxable benefit as it did not come within s. 6(4)||316|
|Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(iii)||payment made as compensation for termination of monthly death benefits was paid, at the least, in lieu of a death benefit||249|
|Tax Topics - General Concepts - Stare Decisis||Supreme Court obiter accorded deference||153|
|Tax Topics - Income Tax Act - Section 9 - Compensation Payments||surrogatum principle references "why the compensatory amount was paid," and not confined to business receipts||207|
|Tax Topics - Statutory Interpretation - Specific v. General Provisions||termination payment that did not come within s. 6(4) should be treated as excluded from s. 6(1)(a)||153|
|Tax Topics - Income Tax Act - Section 6 - Subsection 6(4)||lump sum received as compensation for no longer benefiting from contributions to a group life insurance policy did not come within the terms of s. 6(4)||334|
S. 107.1(b) provides that where an employee benefit plan trust (the "Trust") distributes shares held by the Trust to an employee beneficiary, the...