Alison Spiers, "ECP Planning: Some Practical Considerations", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p 1

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition

Goodwill not transferable separately from business (p.1)

The view of the courts (Herb Payne Transport Ltd. v. MNR, [1963] CTC 116 (Ex. Ct)) is...

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Summary Under
Tax Topics - Income Tax Act - Section 14 - Subsection 14(1)
a purported transfer of goodwill or knowhow separately from the related business may not be effective

Given a judicial view that goodwill is inseparable from the business to which it adds value, it would appear that the accrued gain on goodwill...

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