Words and Phrases - "receive"
Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure)
The appellant, a real estate brokerage firm, determined (based on agreement between its two employees) that the remuneration paid to them would be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227 - Subsection 227(9) | penalty reversed because Crown could not prove the full amount of remuneration re-allocated by it between two employees | 269 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | salary paid into a spouse’s account but available to the taxpayer was constructively received by her | 203 |
| Tax Topics - General Concepts - Onus | s. 227(9) penalty reversed because Crown could not meet the onus on it to establish the full amount on which it imposed it | 233 |
Odette (Estate) v. The Queen, 2021 TCC 65
The appellant estate donated shares of a private company (Edmette), which were non-qualifying securities, to a private foundation with which it...
CAE Inc. v. The Queen, 2021 TCC 57, aff'd 2022 CAF 178
CAE, which was engaged in manufacturing flight simulator systems, incurred over $700 million in R&D expenditures on further developing such...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance | an unconditionally repayable loan with a 2.5% yield was government assistance | 312 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | advance labelled by government as a "contribution" but unconditionally repayable was a loan | 97 |
Borealis Geopower Inc. v. The Queen, 2018 TCC 189 (Informal Procedure)
The taxpayer, a privately owned Canadian corporation involved in geothermal power exploration, development and utilization in Canada, was paid...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | taxpayer had "physically" received govenment assistance funds with freedom to transfer | 109 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(11) | loss carryback did not reduce late-filing penalty or interest | 278 |
Blais v. MNR, 92 DTC 1497 (TCC)
A taxpayer was ordered in 1984 to retain arrears of alimentary allowance that had accumulated from March 1983 onward to be applied against an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | payment references funds transfer | 100 |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) | 100 |
Mbarga v. The Queen, 2005 DTC 1447, 2005 TCC 595 (Informal Procedure)
An amount paid by Alberta Human Resources and Employment directly to the University of Calgary to enable the taxpayer to take a technology program...
The Queen v. British Columbia Forest Products Ltd., 85 DTC 5577, [1986] 1CTC 1 (FCA)
"Parliament has expressly contemplated that a taxpayer may 'receive' assistance from a government in the form of a 'deduction from tax.'" The...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Context | 87 |
Canada v. Innovative Installation Inc., 2010 DTC 5175 [at at 7317], 2010 FCA 285
In order to ensure payment of a loan owing by the taxpayer ("Innovative") to a bank (RBC) on the death of Innovative's principal (Mr Peacock),...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account | receipt of insurance proceeds through debt repayment | 156 |