Words and Phrases - "in lieu of"

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14 February 2008 Internal T.I. 2007-0256401I7 F - Vente d'un surplus actuariel

amount of asset sale price allocated to actuarial surplus was includible under s. 56(1)(a)(i) as being in lieu of refund of such surplus

Before concluding that the portion of the sale price allocated on the sale of a business division to the actuarial surplus in the pension plan was...

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Words and Phrases
in lieu of

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

The former employees and retirees of a bankrupt corporation (the "Employer") received a lump for the cancellation of their rights in a group...

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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 318
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 319
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 353

Scott v. The Queen, 2017 TCC 224

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

In 1980, Nortel had established a health and welfare trust (the “HWT”) for its employees. Following its insolvency and filing under the CCAA...

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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 229
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 181
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) 316
Tax Topics - General Concepts - Stare Decisis Supreme Court obiter accorded deference 153
Tax Topics - Income Tax Act - Section 9 - Compensation Payments surrogatum principle references "why the compensatory amount was paid," and not confined to business receipts 207
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) 153
Tax Topics - Income Tax Act - Section 6 - Subsection 6(4) lump sum received as compensation for no longer benefiting from contributions to a group life insurance policy did not come within the terms of s. 6(4) 334

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

Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at...

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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 168
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 150
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 177

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

The non-resident taxpayer received rents from Canada in 1997 to 2001 without withholding of Part XIII tax, and in 2002 filed returns under s....

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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

Lump-sum damages received by the non-resident taxpayer from Canadian residents for the repudiation, prior to the slated operational commencement...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus no onus to rebut a factual assmption re something not within the taxpayer's purview 170

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

deemed loan proceeds reasonable substitute for accrued interest thereon

The deemed disposition by the taxpayer, as a result of his ceasing to be a resident of Canada, of a loan made by him to a non-resident corporation...

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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

An individual taxpayer, who in two successive years clipped and sold overdue coupons in the amount of $10,000 on his Canada bonds to the trustee...

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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 79