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 |
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...
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 |