sale

Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 53
having equipment owned separately from the services business in which its product is used could permit it to qualify as Class 53 property

Equipment was acquired by a corporation (“Aco”), wholly-owned by a dental surgeon, to manufacture dental restorative products for use as part...

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Words and Phrases
sale
Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition - Paragraph (a)
distinction between a sale and a lease is based on whether legally there is a sale or lease

In providing background on the announcement in Income Tax Technical News No. 5 of the withdrawal of IT-233, CCRA stated:

[T]he purpose of the...

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Words and Phrases
sale

Pharma Coréalis Inc. v. Agence du revenu du Québec, 2023 QCCQ 156, aff'd 2025 QCCA 1346 -- summary under Class 29

Full Title
Pharma Coréalis Inc. v. Agence du revenu du Québec, 2023 QCCQ 156, aff'd 2025 QCCA 1346
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29
putting pharmaceutical companies’ drugs into capsules for clinical tests qualified as manufacturing for sale

The taxpayer (Coréalis) which, in addition to performing R&D services, entered into “service agreements” with pharmaceutical companies (the...

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Words and Phrases
sale

Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068 -- summary under Consideration

Full Title
Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration
consideration for a transfer of waste included the assumption of environmental responsibility

The taxpayer received organic sludge from suppliers in the agri-food industry, and was paid by them for taking over the sludge, which it then...

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Words and Phrases
consideration
sale
Summary Under
Tax Topics - Income Tax Regulations - Regulation 230 - Subsection 230(1) - Sale
a contribution of shares to a TFSA is not a “sale” for Reg. 230 purposes

During the 2019 calendar year, Mr. X withdrew the minimum amount (as defined in subsection 146.3(1)) from his RRIF ($5,000 – so that a T4RIF...

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Words and Phrases
sale

Stark International Inc. v. The Queen, 2019 TCC 248 -- summary under Class 29

Full Title
Stark International Inc. v. The Queen, 2019 TCC 248
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29
oil-processing equipment was for sale even though initial use was to process customer's oil

The taxpayer (“Stark”) used three newly-constructed transformer maintenance trailers (which were 50-foot trailers (“TMT 3, TMT 4 and TMT...

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Words and Phrases
sale

Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC) -- summary under Ownership

Full Title
Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC)
Summary Under
Tax Topics - General Concepts - Ownership
true sale to securitization trust rather than secured loan

A predecessor of the defendant (“BC Tel”) raised $150 million by transferring receivables to a securitization trust (“RAC”) in...

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Words and Phrases
sale
Summary Under
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2)
meaning of sale in Sommerer

Respecting whether CRA accepted Sommerer, it stated that the decision stood:

for the general proposition that where property is transferred to a...

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Words and Phrases
sale

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 SCR 915 (SCC) -- summary under Class 29

Full Title
Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29
supplied asphalt was merely an accession to customers' real property

The taxpayer, which paved driveways, parking lots and small roadways, also operated an asphalt-producing plant. 75% of the output was utilized in...

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Words and Phrases
sale

Renaud v. The Queen, 2010 DTC 1094 [at at 2994], 2010 2010 TCC 76 -- summary under Subsection 62(3)

Full Title
Renaud v. The Queen, 2010 DTC 1094 [at at 2994], 2010 2010 TCC 76
Summary Under
Tax Topics - Income Tax Act - Section 62 - Subsection 62(3)

The taxpayer made an eligible relocation to a residence in another town. Rather than sell his old residence, he rented it, which effected a...

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Words and Phrases
sale

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