Subsection 24(1) - Ceasing to carry on business
Administrative Policy
17 December 2013 External T.I. 2013-0510371E5 F - MCIA / CEC
A taxpayer acquired franchise rights which subsequently became worthless as a result of the bankruptcy of the franchisor. However, it continued to...
9 July 2003 External T.I. 2003-0183675 F - VENTE D'UNE LISTE DE CLIENTS
In one of the alternative scenarios for the sale of the client list of a retiring professional, the sale price is 25% of the fees earned over the...
Words and Phrases
receivable| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | application of s. 12(1)(g) only to excess participating sales price for client list over minimum, or where there is a maximum equaling the client list’s FMV | 369 |
25 August 1994 Internal T.I. 9411027 - TERMINAL ALLOWANCE - ELIGIBLE CAPITAL PROPERTY
Where a taxpayer ceased carrying on a distributing business upon the collapse of the underlying franchisor, it will be a question of fact whether...
IT-471R "Merger of Partnerships" under "Goodwill and Eligible Capital Expenditure"
Subsection 24(2) - Business carried on by spouse or common-law partner or controlled corporation
Administrative Policy
22 April 2008 External T.I. 2005-0152261E5 F - Interaction 24(2) et 14(3)
Regarding a query on the interaction between ss. 14(3) and 24(2) on a transfer of goodwill and an entire business by an individual to a...
21 October 1991 T.I. (Tax Window, No. 12, p. 19, ¶1546)
Neither s. 24(2) nor s. 70(5.1) is elective, and there is no provision permitting the deemed receipt of fair market value proceeds.