Words and Phrases - "disposition"
17 February 2016 External T.I. 2015-0608261E5 - Splitting of a Multiple Life Insurance Policy
Respecting the exercise by a policyholder of a contractual right to split a universal life insurance policy covering two lives into two policies,...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 148 - Subsection 148(10) - Paragraph 148(10)(d) | s. 148(10)(d) does not apply to the exercise of a right to split an insurance policy | 256 |
Buccini v. Canada, 2000 DTC 6685 (FCA)
Following the amalgamation of the taxpayer's employer with other Canadian subsidiaries of the U.S. parent, the taxpayer executed a settlement...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 95 |
The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209
The phrase "the disposition of any property" means the sale of a particular item or items of property and "the expression 'something else' must be...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | "property" includes a contract right, or potentially covenant to deliver knowhow | 78 |
| Tax Topics - Statutory Interpretation - Context | 27 |
The Queen v. Harvey, 83 DTC 5098, [1983] CTC 63 (FCTD)
The taxpayer was found to have disposed of his stock option rights to a corporation for purposes of s. 7(1)(b) when he agreed to surrender them...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 94 |
In re Barne Crown Ltd., [1995] 1 WLR 147 (Ch. D.)
The Court found that in collecting payment upon a cheque from a third party, no disposition of the property of the customer takes place in favour...
Quincaillerie Laberge Inc. v. The Queen, 95 DTC 155 (TCC)
A payment of $575,000 to the taxpayer by a debtor in default in consideration for an extension of the due date of the loan and the taxpayer's...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | amount received for loan extension | 156 |
RCI Environnement Inc.(Centres de Transbordement et de Valorisation Nord-Sud Inc.) v. The Queen, 2008 DTC 4982, 2007 TCC 647, aff'd , 2009 DTC 5940, 2008 FCA 419
The taxpayer made a series of demands for parties to a non-compete agreement (that it had received in connection with its acquisition of a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | no prejudice to taxpayer in amending pleadings | 77 |
| Tax Topics - Income Tax Act - Section 9 - Compensation Payments | negotiated lump sum received for cancellation of non-compete was for diminution in value of goodwill | 61 |
Hewlett Packard (Canada) Ltd. v. Canada, 2004 DTC 6498, 2004 FCA 240
The taxpayer (who had an October 31 fiscal year end) followed a practice of purchasing a new fleet of cars from Ford to replace the fleet which it...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Provincial Law | 89 |
Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)
It was held that since the taxpayer, by executing an agreement respecting the ultimate sale by it of apartment buildings, had "completely divested...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 78 |
Borstad Welding Supplies (1972) Ltd. v. The Queen, 93 DTC 5457, [1993] 2 CTC 266 (FCTD)
In connection with the sale of the taxpayer's business to an arm's length corporation, it was agreed that refillable cylinders would be rented by...