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C.A.E. Inc. v. Canada, 2013 DTC 5084 [at at 5944], 2013 FCA 92

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2013 DTC 5084 [at at 5944], 2013 FCA 92

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Text of decision

Date: 20130417

Docket: A-299-11

Citation: 2013 FCA 92

CORAM: NOËL J.A.

PELLETIER J.A.

MAINVILLE J.A.

BETWEEN:

C.A.E. INC.

Appellant

and

HER MAJESTY THE QUEEN

Respondent

Heard at Montréal, Quebec, on January 17, 2013.

Judgment delivered at Ottawa, Ontario, on April 17, 2013.

REASONS FOR JUDGMENT BY: NOËL J.A.

CONCURRED IN BY: PELLETIER J.A.

MAINVILLE J.A.

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Summaries

Summary Under

Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property

characterization of depreciable property or inventory done on annual basis

The taxpayer leased or entered into leases by it of flight simulators it had manufactured. For financing reasons, it entered into sale and...

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Summary Under

Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a)

change in use on depreciable property conversion to inventory

The taxpayer, which leased flight simulators which it had manufactured, subsequently sold those simulators. The Minister denied capital cost...

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Summary Under

Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a)

applied to conversion of depreciable property into inventory

The taxpayer, which leased flight simulators which it had manufactured, subsequently sold those simulators. The Minister denied capital cost...

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Words and Phrases

Summary Under

Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment

The taxpayer leased or entered into leases by it of flight simulators it had manufactured. For financing reasons, it entered into sale and...

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Summary Under

Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(b)

The taxpayer leased or entered into leases by it of flight simulators it had manufactured. For financing reasons, it entered into sale and...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.