Property

Table of Contents

Cases

Canada v. Haché, 2011 DTC 5089 [at 5848], 2011 FCA 104

The taxpayer voluntarily surrendered two commercial fishing licences under a government program in exchange for a payment. The Court of Appeal...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Rezek v. Canada, 2005 DTC 5373, 2005 FCA 227

A "spread" (under which the taxpayer would purchase a convertible debenture, a convertible preferred share or a warrant and short sell the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] S.C.R. 680

In finding, in his concurring reasons for judgment, that the contractual right of beneficiaries of an estate to enforce an agreement for the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Slobodrian v. Canada (Minister of National Revenue), 2003 DTC 5632, 2003 FCA 350

Before going on to find that a "gift" of services did not qualify as a gift of property, Noël J.A. stated (at p. 5634) that in Manrell, the Court...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128, rev'd 2003 DTC 5225, 2003 FCA 128

A portion of the consideration paid by a purchaser of shares of operating companies in which the taxpayer had been a significant shareholder...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Royal Bank of Canada v. Tuxedo Transport Ltd., 2000 DTC 6501 (BCCA)

In reversing a finding of the chambers judge below, the Court found that his interpretation effectively added words of limitation to the word...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 227 - Subsection 227(4.1) 73

Romkey v. Canada, 2000 DTC 6047 (FCA)

Stone J.A. noted the breadth of the term "property".

La Capitale, Compagnie d'Assurance Générale v. Canada, 98 DTC 6428 (FCA)

Létourneau J.A. found that the right to an indemnity that effectively was being provided by a general insurer to its clients represented property...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Vaillancourt v. The Queen, 91 DTC 5352 (FCTD)

In light of the broad definition of "property", the taxpayer was found to have "property that is a multiple-unit residential building" by virtue...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)

Rent payable for the use and enjoyment of property and a lease stipulating payment of the same were both "property".

Pe Ben Industries Co. Ltd. v. The Queen, 88 DTC 6347, [1988] 2 CTC 120, 88 DTC 6347 (FCTD)

In finding that a payment made by Northern Alberta Railway ("NAR") to the taxpayer as compensation to the taxpayer for the termination by NAR of a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209

Estey, J. stated that the "extremely broad definition of property leaves very little in the 'non-property' classification. It would appear to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The Queen v. Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA)

Notwithstanding the terms of a contract between the taxpayer and an insurance company, funds received by the taxpayer from clients were treated by...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The Queen v. Burgess, 81 DTC 5192, [1981] CTC 258 (FCTD)

Although maintenance granted pursuant to s. 11 of the Divorce Act "is not property in the proper sense of that term", it falls within the broad...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Murphy v. The Queen, 80 DTC 6314, [1980] CTC 386, 80 DTC 6314 (FCTD)

It was held that when the plaintiff gave up a vested right to 1/2 the income of an estate in exchange for being included in a class of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205, 80 DTC 6157 (FCA)

A concept of merchandising replacement muffler systems for automobiles constituted "property".

Rapistan Canada Ltd. v. MNR, 74 DTC 6426, [1974] CTC 495, briefly aff'd 76 DTC 6177, [1976] CTC 296 (SCC)

The American parent or affiliate of the taxpayer purported to grant know-how to the taxpayer by deed of gift. The taxpayer was not entitled to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Quality Chekd Dairy Products Association v. MNR, 67 DTC 5303 (Ex Ct)

The taxpayer, which was a U.S.-resident corporative association of dairy companies, received a fee from a Canadian member that was, in part, a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Huston v. MNR, 61 DTC 1233, [1961] CTC 414 (Ex.Ct.)

An award which the taxpayers received in 1958 from the War Claims Commissioner as compensation for the confiscation of their Czechoslovakian...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Industrial Development Bank v. Valley Dairy Ltd., 53 DTC 1027, [1953] CTC 132 (Ont. S.C.)

S.112(6) of the Act as it read effective prior to July 1, 1950 provided that the liability of a taxpayer for amounts withheld by him "constituted...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
assets

See Also

Carson v. The Queen, 2014 DTC 1006 [at 2520], 2013 TCC 353 (Informal Procedure)

The taxpayer and his wife allowed a charity to use two rooms of their house for free (an office and a storage room), and claimed charitable...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts donated space must constitute an enforceable right in order to be property 123

Winsor v. The Queen, 2008 DTC 2116, 2007 TCC 692

Before going on to find that fishing licences of the taxpayer were capital property, so that an amount received by the taxpayer from the federal...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Roth v. The Queen, 2005 DTC 1570, 2005 TCC 484, aff'd 2007 DTC 5222, 2007 FCA 38

Before going on to find that a purported transfer of an undeveloped project by the taxpayer to a corporation as reflected in a journal entry...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

QEW 427 Dodge Chrysler (1991) Inc. v. Minister of Revenue (2000), 49 OR (3d) 776 (S CT J), aff'd (2002), 50 OR (3d) 460 (S Ct J, Div Ct), 2002 DTC 7228

Chrysler Canada would sell cars to the taxpayer (an automobile dealer) under conditional sales contracts, and sell the conditional sales contracts...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Marzetti v. Marzetti (1994), 26 C.B.R. (3d) 161, [1994] 2 S.C.R. 765

A bankrupt's interest in a post-bankruptcy income tax refund was "property" for purposes of the Bankruptcy Act notwithstanding that the refund did...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Canadian Imperial Bank of Commerce v. Hallahan (1990), 48 BLR 113 (Ont CA)

A milk quota under the Milk Act (Ontario) was not property, and its transfer accordingly could not be challenged under the Fraudulent Conveyances...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Drummond v. Smith (1988), 18 R.F.L. (3d) 120 (Alta. Q.B.)

The word "property" in the Matrimonial Property Act (Alberta) (a term which is not specifically defined) does not include university degrees and...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Re National Trust Co. and Bouckhurst (1987), 61 OR (2d) 640 (C.A.)

A licence to produce tobacco was not property. "The notion of 'property' imports the right to exclude others from the enjoyment of, interference...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Kirby v. Thorn EMI plc, [1987] DTC 462 (CA)

A lump sum which the taxpayer (a British holding company) received as consideration for a non-competition agreement given by it to the U.S....

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

O'Brien v. Benson's Hosiery (Holdings) Ltd. (1979), 53 TC 241 (HL)

A payment of £50,000 by an employee to his employer in consideration of his employer releasing him of all obligations under the employment...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Manitoba Fisheries Ltd. v. The Queen, [1979] 1 S.C.R. 101.

The granting by the Crown to a crown corporation of a commercial monopoly in the export of fish from Manitoba, which had the effect of putting the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)

The sale of property at a price that is less than its value does not result in a transfer of "property" to the purchaser.

Minister of Revenue (Ontario) v. McCreath, [1976] CTC 178, [1977] 1 S.C.R. 2

The settlor of a trust delivered voting trust certificates to the trustee on terms that the income of the trust fund was to be paid during the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] S.C.R. 680

Pigeon J.,in his concurring judgment, indicated that the right of children in an agreement between them and the deceased to require a corporation...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Technical Tape Corp. v. MNR, 64 DTC 428 (TAB)

Variable payments made by the taxpayer for the use by it of know-how provided by a U.S. corporation were subject to withholding tax as being "for...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Minister of National Revenue v. Fitzgerald, [1949] CTC 101, [1949] S.C.R. 453 (SCC)

A testator (A) domiciled and resident in British Columbia, who died in 1921, bequeathed his property to his surviving wife (B), with the assets of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Federal Commissioner of Taxation v. United Aircraft Corp. (1943), 7 A.T.D. 318 (HC)

Licence fees to be earned by an American company for the communication of know-how to an Australian licensee did not represent income from a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) provision of knowhow in the US to Australian company not carrying on business in Australia 195

Musker v. English Electric Co. Ltd., 41 TC 556 (HL)

Lord Radcliffe stated (p. 585):

"There is no property right in 'know-how' that can be transferred, even in the limited sense that there is a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Nokes v. Doncaster Amalgamated Collieries Ltd., [1940] A.C. 1014 (HL)

It was held that where a court order was made under the Companies Act 1929, for the amalgamation of two corporations, including an order for the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
property property acquired

Curtis Brown, Ltd. v. Jarvis (1929), 14 TC 744 (K.B.D.)

Rowlatt J., before going on to find that U.K. income tax should have been deducted from the payment of royalties to non-resident authors on the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) 119

Administrative Policy

29 November 2016 CTF Roundtable Q. 8, 2016-0671501C6 - 55(2) clause 55(2.1)(b)(ii)(B)

CRA indicated that cash is property for s. 55 purposes.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) cash is property for 55(2.1)(b)(ii)(B) purposes 133

3 March 2015 External T.I. 2014-0519981E5 F - Donation avec charge / Gift with a charge

Before considering the treatment under ss. 69(1)(b)(ii) and s. 69(1)(c) of a gift of a real estate property that is charged with a hypothec, CRA...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) gift of encumbered property 153

12 June 2012 STEP CRA Roundtable, 2012-0442921C6 - STEP CRA Roundtable - June 2012 Q.9

A s. 70(6) election cannot be made in respect of a fractional interest in a property For these purposes each share of a corporation, and all of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

19 January 2011 External T.I. 2010-0390831E5 - Compute LRIP - corporation becomes non-CCPC

A future income tax asset is not "property" within the meaning of variable A of s. 89(8) as it does not represent a "right" - unless the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

1998 A.P.F.F. Round Table, Q. 14, No. 9824750

Know-how is not property. Accordingly, although the know-how relating to a business may be part of the goodwill that is transferred on an...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

27 April 1998 TI 980014

A lump-sum payment received by the individual shareholder of a corporation upon a sale by that corporation of one of its business divisions and in...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

23 September 1996 External T.I. 5-962304

The rights of a person to obtain a patent in respect of know-how represent property and, accordingly, can qualify as an eligible property under s....

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) pre-patent right included 27

8 November 1995 Memorandum 952507

In considering the treatment of payments received by a shareholder pursuant to a non-competition agreement, the Department stated:

"Property is...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

24 April 1995 T.I. 942950 (C.T.O. "Milk Quota")

A milk quota represents a "right" of the individual farmer to produce and market milk and, therefore, represents "property" and an "eligible...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

29 March 1995 Memorandum 950250 (C.T.O. "Right to Royalty Eligible Property")

RC cited Evans v. MNR,60 DTC 1047, [1960] S.C.R. 391 and Asamera Oil (Indonesia) Ltd.,73 DTC 5274 (FCTD) after stating that "a right to receive...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) 75

3 October 1994 External T.I. 5-942411

A contingent right to receive shares under an employee profit sharing plan would be a capital property the disposition of which to give rise to a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 34

24 March 1992 T.I. (920203 (March 1993 Access Letter, p. 76, ¶C109-126; Tax Window, No. 18, p. 24, ¶1827)

A particular covenant that is a restriction against land and which runs with the land and is binding on the landlord and his successors in title,...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

81 C.R. - Q.86

notwithstanding Rapistan, RC will consider know-how that is of a capital nature as being "eligible capital property" for purposes of the Act.

Articles

Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377

Discussion of the realization principle.

Wilson, "Tax Treatment of Development, Acquisition, and Transfer of Technology", 1983 Conference Report, pp. 857-867

Discussion of whether know-how is property.

Navigation