Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
