Miller – Tax Court of Canada accepts that software was to be valued at its purchase price

A PhD purchased software from a promoter entity in 2003 for $7,000 and immediately donated it to a registered charity, and was issued a tax receipt for $42,000. In confirming CRA’s reduction in the gift amount to $7,000, Owen J applied the dictum in Nash that “where the dates of acquisition and disposition are very close in time, barring evidence to the contrary, the cost of acquiring the asset will likely be a good indicator of its fair market value.”

Neal Armstrong. Summary of Miller v. The Queen, 2019 TCC 204 under s. 118.1(1) – total charitable gift.