Subsection 82(1) - Taxable dividends received
Paragraph 82(1)(a)
Cases
De Groote v. The Queen, 85 DTC 5008, [1985] 1 CTC 687 (FCTD)
The taxpayer sold the beneficial ownership of shares to, and executed a declaration of trust in favour of, a company controlled by him and then,...
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 47 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 92 |
Robson v. Minister of National Revenue, 52 DTC 1088, [1952] CTC 85, [1952] 2 S.C.R. 223
A corporation, which admittedly was seeking to effect a tax-free distribution of profits to its shareholders, sold shares of another corporation...
See Also
Cooper v. The Queen, 2010 TCC 403, 2010 DTC 1277 [at 3934] (Informal Procedure)
Webb J. noted that the gross-up amount will increase a taxpayer's income for the purposes of assessing a 163(1) penalty, because 163(1) calculates...
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) | 73 |
Horkoff v. The Queen, 97 DTC 621 (TCC)
Dividends that were purportedly paid to the taxpayers "as of" December 30, 1990 were dividend income to the taxpayers in their 1991 taxation years...
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| Tax Topics - General Concepts - Effective Date | 65 |
C.I.R. v. Trustees of Joseph Reid (1949), 30 TC 431 (HL)
In finding that a dividend paid by a South African company out of a capital gain realized by it was "income arising from possessions out of the...
Gresham Life Society Co., Ltd. v. Bishop (1902), 4 TC 464 (HL)
The taxpayer, a UK life insurance company which was managed in London and had foreign branch businesses, was assessed for interest and dividends...
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| Tax Topics - General Concepts - Payment & Receipt | no constructive receipt | 204 |
Administrative Policy
30 January 2014 External T.I. 2013-0515761E5 F - Dividend received
A dividend of a taxable Canadian corporation owned by an individual is not paid in money but is recorded in its books as an increase in a loan...
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| Tax Topics - General Concepts - Payment & Receipt | book entry dividend | 138 |
11 December 2013 External T.I. 2013-0474161E5 - T-slips and dividend and interest
Respecting a question as to when dividends are paid and received for T5 purposes, CRA stated:
In Innovative Installation Inc. v The Queen, 2009...
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| Tax Topics - General Concepts - Payment & Receipt | constructive receipt | 102 |
25 September 2013 External T.I. 2013-0488571E5 F - Repayment of a dividend
A taxpayer refunded part of the dividends received from a corporation in 2006.
After citing Sussex Square Apartments v. The Queen. [1999] 2 CTC...
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| Tax Topics - General Concepts - Effective Date | 107 |