29 June 1999 Internal T.I. 9913180 F - AFFACTURAGE -- attach -- Debt/ receivables
sale of trade receivables to securitization vehicle generally on income account
Debt/ receivables
Dally (C.) v. M.N.R., [1991] 1 CTC 2556 -- attach -- Debt/ receivables
debt of an insolvent corporation acquired for $1 in connection with an adventure
17 July 2001 External T.I. 2000-006174 F - BIENS D'INVENTAIRE -- attach -- Debt/ receivables
Ensite and Marconi exceptions to corporate investments of earnings being held on capital account
12 April 2002 External T.I. 2002-0122495 F - PRIME PAYEE SUR OBLIGATION -- attach -- Debt/ receivables
short holding time to maturity does not preclude a bond from being capital property
30 October 2006 Internal T.I. 2006-0199721I7 F - Escompte sur vente de compte clients -- attach -- Debt/ receivables
the sale of receivables that were generated on income account is on income account
Loans - Commentary
Treatment of mortgage and other loan discounts
84 C.R. - Q.41 -- attach -- Debt/ receivables
Barrington Lane Developments Limited v. The Queen, 2010 TCC 388, 2010 DTC 1244 [at at 3734] -- attach -- Debt/ receivables
MNR v. Mandelbaum, 62 DTC 1093 (Ex Ct) -- attach -- Debt/ receivables
purchase and resale of conditional sales contracts were "similar to the kind of transactions that dealers in mortgages and agreements engaged in" and were on income account
Finley, "Investment in Strip Bonds May Allow Capital Gain", Taxation of Executive Compensation and Retirement, October 1991, p. 503. -- attach -- Debt/ receivables
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