option

Armour Group Limited v. Canada, 2018 FCA 134 -- summary under Contract or Option Cancellation

Full Title
Armour Group Limited v. Canada, 2018 FCA 134
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation
lump sum paid on the acquisition of a property subject to a ground lease to the purchaser group coupled with the ground lease surrender did not generate a lease termination deduction

A bare trustee (“FSL”) for the taxpayer (an investment and real estate company) had received a ground lease of property in downtown Halifax...

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Words and Phrases
option
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (f)
assigning right to purchase Canadian real estate is disposing of tcp

Would an assignment to a trust by a non-resident person of a right to purchase a Canadian apartment unit be considered a disposition of taxable...

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Words and Phrases
option transfer

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 SCR 187 -- summary under Subsection 49(1)

Full Title
Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187
Summary Under
Tax Topics - Income Tax Act - Section 49 - Subsection 49(1)

Before finding that a clause in a lease giving the lessee the unilateral right to compel the lessor to sell helicopters to the lessee at their...

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Words and Phrases
option
exercise
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