Taylor v Provan

Subject Matter

REVENUE — Income tax — Employment — Expenses of trade or profession — Canadian resident unpaid director of company in England — Travelling expenses reimbursed — Whether travelling in performance of duties of office — Income Tax Act 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), s. 160 (1), Sch. 9, para. 7

[1972] 1 WLR 1459; [1972] 3 All ER 930, Ch D

REVENUE — Income tax — Employment — Emoluments — Expenses of trade or profession — Canadian resident unpaid director of company in England — Special assignment involving travelling to England — Travelling expenses reimbursed — Whether travelling in performance of duties of office — Whether duties in respect of special assignment to be differentiated from duties as director — Whether travelling expenses “necessarily incurred” in performance of duties of office — Whether paid in respect of duties performed in United Kingdom — Income Tax Act 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), ss. 156, 160 (1), Sch. 9, para. 7

[1973] Ch 388; [1973] 2 WLR 675; [1973] 2 All ER 65, CA

REVENUE — Income tax — Employment — Emolument — Canadian resident unpaid director of company in England — Special assignment involving travelling to England — Travelling expenses reimbursed — Whether duties in respect of special assignment to be differentiated from duties as director — Whether payments in respect of duties performed in United Kingdom — Income Tax Act 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), ss. 156, 160 (1)

[1975] AC 194; [1974] 2 WLR 394; [1974] 1 All ER 1201, HL(E)

REVENUE — Income tax — Expenses of employment (Schedule E) — Unpaid director of company in England resident in Canada — Special assignment involving travelling to England — Travelling 195expenses reimbursed — Whether travelling expenses “necessarily incurred” in performance of duties of office — Income Tax Act 1952. Sch. 9, para. 7

[1975] AC 194; [1974] 2 WLR 394; [1974] 1 All ER 1201, HL(E)

Appellate History