Cases
Schwartz v. Canada, 96 DTC 6103, [1996] 1 SCR 254
An individual who had entered into a contract of employment was not, at that time, an employee because under the definition, an individual does...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) | no deference to FCA factual findings | 95 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | pre-employment termination damages were not a retiring allowance | 62 |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | 53 | |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) | quaere whether income can be from a non-enumerated source | 45 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 83 | |
| Tax Topics - Income Tax Act - Section 68 | 95 | |
| Tax Topics - Statutory Interpretation - Comparison of Provisions | presumption of consistent expression within same statute | 73 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | specific statutory rule should not be undercut by a more general rule | 76 |
Scott v. The Queen, 94 DTC 6193, [1994] 1 CTC 330 (FCA)
The taxpayer, who was the Director and Secretary-Treasurer of a public corporation ("Night Hawk") and whose work as corporate secretary (for which...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(5) | 222 |
The Queen v. Kuhl, 74 DTC 6024, [1973] CTC 846 (FCTD)
"The definition of employment ... clearly requires a master and servant relationship."
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 29 | |
| Tax Topics - General Concepts - Tax Avoidance | 13 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | 75 | |
| Tax Topics - Income Tax Act - Section 3 | 54 |
See Also
Blaker v. The Queen, 93 DTC 1025, [1994] 1 CTC 2242 (TCC)
A lump sum of $90,000 received by the taxpayer in consideration for his resignation from a governor-in-council appointment to the National Parole...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | 55 |
Administrative Policy
9 April 1999 Income Tax Severed Letter 9906056 F - FRAIS LÉGAUX/RÉGIME D'ASSURANCE-SALAIRE
Legal fees incurred by the taxpayer to recover benefits under a salary insurance plan were not deductible under s. 8(1)(b), given that the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) | legal fees incurred to recover salary insurance plan benefits were non-deductible | 52 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | s. 18(1)(a) applied on the basis of the main reason for which expense incurred | 118 |