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., 2002 DTC 7517, 2002 FCA 408-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital cost of assets purchased with treasury shares was the agreed purchase price being the shares’ stated capital In connection with a privatization transaction and at a time that it was still owned by the federal Crown, the taxpayer purchased assets for a stipulated purchase price that was less than the price at which an arm's length purchaser had committed (pursuant to the same agreement under which the asset sale occurred) to purchase the common shares of the taxpayer. ...

., 2002 DTC 7517, 2002 FCA 408-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base cost of assets acquired was the stated capital of the shares issued therefor, being the agreed transaction value In connection with a privatization transaction and at a time that it was still owned by the federal Crown, the taxpayer purchased assets for a stipulated purchase price that was less than the price at which an arm's length purchaser had committed (pursuant to the same agreement under which the asset sale occurred) to purchase the common shares of the taxpayer. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose finding an acquirer to maximize shareholder value The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) The taxpayer paid a fee to a financial advisor, calculated as 0.7% of the market value of its equity and of the amount of its long-term debt net of working capital, in consideration for advice provided in connection with considering alternatives to maximize shareholders' value, with an emphasis on merger possibilities. ...

" In light of the fact that the taxpayers were members of two Amway networks which had their bases in North Carolina and Maine, the expenses they incurred in attending the meetings in the U.S. were found to have been incurred in connection with their business and in a location reasonably consistent with the territorial scope of the two organizations. ...

The Queen, 95 DTC 164 (TCC), briefly aff'd 97 DTC 5012 (FCA)-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Legal and accounting fees paid by the taxpayer in connection with the preparation of management circulars, which were sent to shareholders in response to three take-over bids, were fully deductible. ...

MNR, 91 DTC 1286 (TCC)-- summary under Paragraph 212(4)(b) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(b) Beaubier J. affirmed the disallowance by the Minister of all but $100,000 per year of amounts paid by a Canadian subsidiary to its U.S. parent which allegedly were reimbursements of expenses incurred by the parent in connection with litigation involving the Canadian subsidiary, and for accounting, administrative and sales services, and for overheads, of the U.S. parent. ...

Expense- Start-Up and Close-Down Expenditures The taxpayer, which had a 25% interest in an oil field under the North Sea, was not permitted to deduct a provision for the estimated costs to be incurred at a future date, on completion of production, in order to: restore to their original condition rigs and tankers that it had leased and adapted for use in connection with extracting or transporting the oil; removing a manifold, loading lines and buoy from the area; and capping wells and removing well heads. ...

The Queen, 2006 DTC 3431, 2006 TCC 347, aff'd supra 2008 DTC 6017, 2007 FCA 370-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) appreciation in warrants allocated to employees on capital account The taxpayer's employer ("Canaccord"- a broker dealer) was issued broker compensation warrants in connection with an equity treasury financing by a Canaccord client, and Canaccord allocated a portion of those warrants to the taxpayer as compensation for his employment services. ...