Subsection 110.1(1) - Deduction for gifts
Paragraph 110.1(1)(a) - Charitable gifts
Cases
Hudson Bay Mining and Smelting Co., Ltd. v. The Queen, 86 DTC 6244, [1986] 1 CTC 484 (FCTD), aff'd 89 DTC 5515 (FCA)
The sale by the taxpayer to the Manitoba Hydro-Electric Board of hydro facilities for what was agreed upon in the negotiations to be a net price...
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 81 |
Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085 (FCTD)
Gifts which the taxpayer made to Jewish organizations in the Montreal area in amounts over $100 were accepted to have been made for the purpose of...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | donations deductible as business expenses rather than as gifts | 92 |
See Also
Emballages Starflex Inc. v. Agence du revenu du Québec, 2016 QCCA 1856
The taxpayer had claimed deductions for donations made to U.S. charities based on a Quebec provision which exempted income for Quebec purposes if...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | gifts to charities likely cannot be deducted as business expenses | 207 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | charitable gift rules a complete code | 144 |
Pustina v. The Queen, 96 DTC 1594 (TCC)
Mogan TCJ. indicated that if a car dealer donated a new car to a local charity that issued a charitable receipt, the deemed proceeds to the dealer...
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| Tax Topics - General Concepts - Fair Market Value - Other | 117 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | paintings acquired for donation | 96 |
Administrative Policy
18 November 2003 External T.I. 2003-001469
The grant of a stock option by a corporation would not appear to result in a reduction in the granting corporation's assets. This would preclude...
29 January 1997 T.I. 963494
General discussion of the circumstances in which a corporate donation to an Indian band council (which RC recognizes as a Canadian municipality...
6 June 1994 T.I. 933590 (C.T.O. "Corporate Gift of a Life Insurance Policy"
Where a corporation purchases a large whole life insurance policy in respect of one of its key employees and gifts the policy to a charity so that...
9 July 1993 T.I. 930660 (C.T.O. "Whether Corporation can make Donation Rather than Estate"; Tax Window, No. 33, p. 6, ¶2641)
Where a corporation makes a charitable donation in lieu of the estate holding its shares making such donation, the donation by the corporation may...
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 54 |
IT-110R2 "Deductible Gifts and Official Donation Receipts"
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(2) | 0 | |
| Tax Topics - Income Tax Regulations - Regulation 3501 | 0 |
Articles
Alan Steinfeld, Stephen Moverley, "When is a Gift Completed?", All England Legal Opinion, No. 10, July 2001.
Paragraph 110.1(1)(b) - Gifts to Her Majesty
Administrative Policy
ATR-63, 20 April 1995 "Donations to Agents of the Crown"
In the absence of a specific provision to this effect in an organization's enabling legislation, RC required an opinion from the Deputy Attorney...
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Crown Gifts | 96 |
20 January 1995 External T.I. 5-950041
Given that s. 53 of the College and Institute Act, R.S.B.C. 1979, c. 53 provided that an institution was for all its purposes an agent of the...
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Crown Gifts | 58 |
16 December 1992 T.I. 923559 (C.T.O. "Crown Gifts to Agents of Her Majesty")
A gift to a foundation established under the University Foundation Act (Ontario) qualifies as a gift to an agent of the provincial Crown.
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Crown Gifts | 27 |
Paragraph 110.1(1)(d)
Administrative Policy
4 April 2016 Internal T.I. 2016-0625241I7 F - Application of section 207.31
Respecting a proposed disposition of ecologically sensitive land by a municipality without authorization of the Minister of the Environment, which...
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| Tax Topics - Income Tax Act - Section 207.31 | tax on sales of ecological lands applies even if no deduction was claimed | 130 |