General Construction Co. Ltd. v. Minister of National Revenue, 59 DTC 1169, [1959] CTC 300, [1959] S.C.R. 729 -- summary under Compensation Payments

Shortly before the completion of a joint venture relating to the construction of a portion of a pipeline, the taxpayer, rather than agreeing to receive an interest in the machinery and equipment which was used in the joint venture, agreed to receive a return of its capital contributions to the joint venture plus an additional sum of $90,000 which, it was found, represented an estimate of the profit which it would have been entitled to receive upon the winding-up of the joint venture. Martland J. held that the sum of $90,000 was taxable given that the taxpayer, which made a business of entering into joint ventures with a view to profit, entered into the joint venture in question with the intention of recouping its investment plus a profit at the conclusion of the venture, and the $90,000 represented such a profit.