Words and Phrases - "commission"

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Canada v. Rio Tinto Alcan Inc., 2018 FCA 124

deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company
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Words and Phrases
commission specific shares
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management dealer and professional fees incurred by a public board in determining to make a bid, as contrasted to implementation, were currently deductible 336
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular was not a financial report 154

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

investment dealer fees re advisability of making hostile takeover were fully deductible
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Words and Phrases
commission
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 228
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Enterprise Foundry (N.B.) Ltd. v. MNR, 64 DTC 660 (TAB)

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Words and Phrases
commission
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) employee with general authority to contract based on authorized prices and with authority over inventory in independent warehouse was PE 275

Griesbach v. Canada (M.N.R.), 91 DTC 142 (TCC)

commissions must be tied to sales volume; bonus based on gross profit was not commission
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Words and Phrases
commission

Consumers' Gas Co. v. MNR, 65 DTC 5138, [1965] CTC 225 (Ex Ct), briefly aff'd 67 DTC 5196 (SCC)

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Words and Phrases
commission

MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

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Words and Phrases
commission in the course of