Devon Canada Corporation v. The Queen, 2018 TCC 170 -- summary under Eligible Capital Expenditure
Summary Under
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditurepayments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it
Two public-company predecessors by amalgamation of the taxpayer made cash payments for the surrender by employees of their options previously...
Words and Phrases
cost| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) | quaere whether “sale” includes a sale to a 3rd party | 177 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) | stock option surrender payments of target deductible under s. 111(5.2) | 62 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | disposition of surrendered stock options occurred under doctrine of merger | 318 |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | "cost" implies the acquisition of an asset | 172 |