Words and Phrases - "incur"
ExxonMobil Canada Resources Company v. The King, 2026 TCC 42
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expensetaxpayer incurred costs as a result of a partial assignment to it of an agreement for conducting a feasibility study
The US parent of the taxpayer (“EM Corp.”), and two other oil and gas companies (“BP Alaska” and “Phillips Alaska”) entered into an...
Words and Phrases
incur| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | non-suit motions should not be entertained after the close of evidence | 178 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) | the reassessed feasibility costs of the Cdn taxpayer were incurred by it as a result of an assignment of an interest in the related project agreement to it by its NR parent | 341 |
| Tax Topics - General Concepts - Evidence | in the absence of evidence as to the effect of Alaskan law, lex fori was applied | 89 |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) | the taxpayer’s costs for a pipeline feasibility study were incurred in relation to a source of income (the pipeline or use of the information generated) | 327 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | income-producing purpose can be secondary | 247 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(b) | taxpayer was assigned a portion of a pipeline feasibility project as a likely Canadian participant in any pipeline, and the alternative fee-for-services model was not well established | 268 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | pleading of Part XIII tax arising from the conferral of a benefit was sufficient to ground a Crown argument that the benefit arose under s. 56(2) | 314 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | entering into a bona fide transaction with a shareholder does not entail the conferral of a benefit | 94 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | s. 246(1) cannot satisfy the “benefit” requirement of s. 56(2) so as to engage s. 214(3)(a) | 269 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) - Paragraph 246(1)(b) | s. 246(1)(b) benefit is not deemed to be a dividend | 265 |
| Tax Topics - Income Tax Act - Section 214 - Subsection 214(3) - Paragraph 214(3)(a) | s. 214(3)(a) does not deem a s. 56(2) or 246(1) benefit to be a dividend | 286 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(a) | terms of cross-border agreement for the sharing of the costs of a pipeline feasibility study were commercially appropriate | 366 |
9 August 2023 External T.I. 2023-0979431E5 - CEDOE - "costs incurred by a person"
mark-up in the charges for geophysical services by a connected corporation to an exploration company over its incurred costs would be excluded as CEDOE
BCO will be issuing flow-through shares to fund exploration work. A second company (ACO), which is wholly owned by the controlling shareholder of...
Words and Phrases
incurLewski v Commissioner of Taxation, [2017] FCAFC 145
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expenseobligation to pay purchase price was incurred on agreement date rather than subsequent closing
On June 30, 1999, a trust of which the taxpayer was a beneficiary had a 40% (later reduced to 2%) interest in a syndicate (that entered into an...
Words and Phrases
incur| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 104 - Subsection 104(24) | an alternate resolution that the taxpayer was not entitled to an income distribution if Revenue denied a trust deduction made her entitlement contingent and non-includible | 374 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) | since the taxpayer through her husband as agent had knowledge of an income distribution, her subsequent purported disclaimer was not immediate | 304 |
| Tax Topics - Income Tax Act - Section 104 - Subsection 104(13) | a trust income declaration that was subject to a tax contingency did not result in an income inclusion to the beneficiary | 149 |
| Tax Topics - General Concepts - Agency | knowledge of agent imputed to principal | 217 |
6 December 2016 External T.I. 2015-0589041E5 F - Frais médicaux payés d’avance - prepaid medical expenses
Summary Under
Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a)prepaid expenses not recognized before incurred
What impact does the timing of payment of medical expenses have on the computation of the medical expense tax credit ("METC") in s. 118.2(1),...
Words and Phrases
incur| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(1) | example of the election to claim medical expenses (that are not a prepayment for a future year’s services) on a lagged basis | 183 |
10 January 2014 Internal T.I. 2013-0505911I7 - Meaning of "assembly project" in Brazil Convention
"assembly" and "installation" project
Art. V, subpara. 2(g) of the Canada-Brazil Treaty included an "assembly project" in the definition of permanent establishment, rather than using...
The Queen v. Burnco Industries Ltd., 84 DTC 6348, [1984] CTC 337 (FCA)
The taxpayer was obligated under an agreement with a municipality to replace earth that it removed in the process of excavating a gravel pit....
C.I.R. v. Lo and Lo, [1984] B.T.C. 281 (PC)
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timingaccrued retirement obligation
Each long-term employee of a law firm was entitled, upon retirement, to a lump-sum payment from the firm roughly equivalent to 1/24 of his annual...
Edmonton Liquid Gas Ltd. v. The Queen, 84 DTC 6526, [1984] CTC 536 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expenseexpense incurred as no refund rights
MacGuigan JA rejected the position of the Minister that amounts paid to a drilling operator in 1974 for drilling work to be performed in 1975 did...
Ensign Tankers (Leasing) Ltd. v. Stokes, [1989] B.T.C. 410 (Ch.D.)
At 477:
"'To incur' means 'to render oneself liable to'."