Words and Phrases - "in lieu of"

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13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices

damages received by former employees of insolvent company for cancellation of their life insurance coverage were received in lieu of remuneration for their employment services

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Words and Phrases
in lieu of arises pursuant to
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) damages received after 2011 by employees of an insolvent company for cancellation of their medical plan have become taxable 306
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit damages received for loss of life insurance coverage were not rendered a death benefit under the surrogatum principle 303
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) legal fees paid to recover damages for employer cancellation of insurance coverage, and medical plan, qualified and did not qualify, respectively 337

Scott v. The Queen, 2017 TCC 224, 2017 TCC 224

payment made as compensation for termination of monthly death benefits was paid, at the least, in lieu of a death benefit

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Words and Phrases
in lieu of
Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 89 - Subsection 89(1) - Paragraph 89(1)(a) trust return not admitted at trial opening where no previous notice and not relied upon by CRA 211
Tax Topics - Income Tax Act - 101-110 - Section 107.1 - Paragraph 107.1(a) s. 107.1(a) in effect produced a rollover on cash distribution of mooted benefits 175
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) a distribution from a health and welfare trust to compensate for lost insurance coverage was not a taxable benefit as it did not come within s. 6(4) 304
Tax Topics - General Concepts - Stare Decisis Supreme Court obiter accorded deference 129
Tax Topics - Income Tax Act - Section 9 - Compensation Payments surrogatum principle references "why the compensatory amount was paid," and not confined to business receipts 191
Tax Topics - Statutory Interpretation - Specific v. General Provisions termination payment that did not come within s. 6(4) should be treated as excluded from s. 6(1)(a) 141

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind

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Words and Phrases
in lieu of on account of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain 156
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 138
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits 169

Pechet v. Canada, 2009 DTC 5189, 2009 FCA 341

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Words and Phrases
in lieu of

Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104

damages to lessor for advance lease repudiation were in lieu of rent

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 59

Holzhey v. The Queen, 2008 DTC 2607, 2007 TCC 247

deemed loan proceeds reasonable substitute for accrued interest thereon

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Words and Phrases
in lieu of

Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)

sale of matured interest coupons gave rise to interest receipt or amount in lieu

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Words and Phrases
in lieu of
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt interest coupons required to be presented 77