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BlackBerry Limited v. The King, 2024 TCC 123 -- summary under Paragraph 95(3)(b)

Full Title
BlackBerry Limited v. The King, 2024 TCC 123
Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b)
s. 95(3)(b) exclusion applied where inbound R&D services from US subsidiaries were inextricably linked with product sales

The taxpayer (“BlackBerry”), which in its 2010 taxation year generated $8 billion in sales of smartphones to BlackBerry US, which on-sold...

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Words and Phrases
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Summary Under
Tax Topics - Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program
“period” referred to the times at which the individual was receiving income from employment

The Directorate indicated that the word “period” in the pre-2004 version of para. (b) of the definition of “qualifying educational...

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period in connection with

ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA -- summary under Paragraph 141.1(3)(a)

Full Title
ONEnergy Inc. v. The Queen, 2016 TCC 230, rev'd 2018 FCA
Summary Under
Tax Topics - Excise Tax Act - Section 141.1 - Subsection 141.1(3) - Paragraph 141.1(3)(a)
services acquired long after the cessation of commercial activity may give rise to input tax credits

The appellant (“Look”), which had been carrying on a telecommunications business, sold its licences (including its “Spectrum” licence) ,...

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Words and Phrases
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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b)
prototype testing services not directly related to sales of improved product

A foreign affiliate ("FA1") of a Canadian manufacturer (the "Taxpayer") provides testing services to the Taxpayer on products (namely, prototypes)...

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Reiner v. The Queen, 2005 DTC 308, 2005 TCC 115 (Informal Procedure) -- summary under Qualifying Educational Program

Full Title
Reiner v. The Queen, 2005 DTC 308, 2005 TCC 115 (Informal Procedure)
Summary Under
Tax Topics - Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program

The taxpayer, who was a full-time teacher, also was pursuing a course of studies at a U.S. university leading to a Master of Arts in Curriculum...

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