to incur

10 January 2014 Internal T.I. 2013-0505911I7 - Meaning of "assembly project" in Brazil Convention -- summary under Article 5

Art. V, subpara. 2(g) of the Canada-Brazil Treaty included an "assembly project" in the definition of permanent establishment, rather than using the term "installation project." After noting that this provision likely was based on Art. 5 of the 1963 OECD Model, which used "assembly project," before this was changed in 1977 without comment to "installation project," referring to dictionary definitions of "assemble" and "install," and noting that the French Treaty versions generally used "montage" for both terms, CRA stated:

By services, 28 November, 2015

The Queen v. Burnco Industries Ltd., 84 DTC 6348, [1984] CTC 337 (FCA) -- summary under Timing

The taxpayer was obligated under an agreement with a municipality to replace earth that it removed in the process of excavating a gravel pit. However, the taxpayer did not enter into a contract with a contractor to have the required "backfilling" work done until after the end of the taxation year. It was held that the taxpayer had not "incurred" an expense equal to the estimated cost of backfilling because "an expense cannot be said to be incurred by a taxpayer who is under no obligation to pay money to anyone."

to incur