Words and Phrases - "gift"

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24 January 2019 External T.I. 2018-0773301E5 - Paragraph 69(1)(c) and Nominal Consideration

a transfer structured as a sales agreement for nominal consideration may qualify as a gift
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Words and Phrases
gift

Fonds de solidarité des travailleurs du Québec (F.T.Q) v. The Queen, 2018 TCC 3, aff'd on s. 18(1)(a) grounds 2019 CAF 36

consideration for "gift" was elimination of obligation to invest the funds
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Words and Phrases
gift
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose purpose of payment was to extricate from a regional economic-development obligation rather than to enhance business reputation 220
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts payment relieving of a correlative contractual obligation was not a gift 120

Cassan v. The Queen, 2017 TCC 174

gratuitous transfer is gift irresepctive of absence of benevolent intent
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Words and Phrases
gift
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance 466
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) loans were not bona fide in that not handled with commerciality 655
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable 577
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time 583
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67

French v. Canada, 2016 FCA 64

Parliament may have intended what constitutes a gift outside Quebec to be partly informed by the Civil Code
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Words and Phrases
gift
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 Parliament may have intended what constitutes a gift outside Quebec to be partly informed by the Civil Code 165

26 June 2013 External T.I. 2013-0490711E5 F - Disposition en contrepartie de 1$

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Words and Phrases
gift

16 April 2013 External T.I. 2013-0477981E5 F - Interpretation of Gift

ability to opt out of a compulsory contribution to an employer-aligned charity would not necessarily establish a “gift”/Quebec “gift” is CCQ “donation”
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Words and Phrases
gift don

The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)

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Words and Phrases
gift

Berry v. Warnett, [1980] T.R. 299 (C.A.), rev'd [1980] BTC 239 (HL)

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Words and Phrases
gift