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La Reine, 2007 DTC 1534, 2007 TCC 461 (Informal Procedure)-- summary under Start-Up and Liquidation Costs Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs Before going on to find that legal fees incurred as a result of a cancellation by the taxpayer of an agreement to purchase a building were capital expenditures, Paris J. rejected a submission that they should not be considered to have been incurred in connection with a source of business. ...

La Reine, 2007 DTC 1534, 2007 TCC 461 (Informal Procedure)-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) Before going on to find that legal fees incurred as a result of a cancellation by the taxpayer of an agreement to purchase a building were capital expenditures, Paris J. rejected a submission that they should not be considered to have been incurred in connection with a source of business. ...

Bentley was considered under the Finance Act 1965 to have acquired, on her father's death in 1967, a 1/6 share of real property situate in West Germany which passed to her for a consideration equal to its fair market value, and sold her interest for DM in 1973. ...

Such expenditures cannot in any way be considered as being for minor repairs or regular maintenance. ...

In finding that the portion of the assets acquired through the issue of the special shares should be considered to have a cost to the taxpayer of $1,000, Rip T.C.J. stated (at pp. 2510-2511) that "it is the directors who determine the stated capital of shares and the consideration for the issue of the shares", and further noted that the date of payment of the dividend might have been delayed indefinitely until the directors determined to pay it. ...

., 2015 ONSC 7189-- summary under Paragraph 6204(1)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(a) board had discretion to determine fixed liquidation entitlement In addition to denying the s. 110(1)(d) deduction on the basis that executives had sold their optioned shares to a specified person (who on-sold to the arm’s length purchaser of the corporation, namely, Rogers), rather than directly to Rogers, CRA also considered that the shares were not prescribed shares because the Board on liquidation had the discretion to establish a fixed liquidation amount for the shares. ...

These carrying charges can be considered as part of the cost of acquiring and disposing of the shares. ...

The court considered whether the covenant could be rectified on the basis that the term "Metropolitan City of Vancouver" mistakenly described the geographic scope of the covenant, and denied rectification because the parties did not have a prior oral agreement regarding the geographic scope of the covenant and the parties did not mistakenly describe something else in the written contract. ...

Noël CJ considered that premium amortization did not accord with mark-to-market accounting, and directed the Minister to reassess on the basis that the taxpayer was entitled to use the mark-to-market accounting, but without deferring or amortizing any portion of the premiums paid or received during 1998. ...

The Queen, 2016 TCC 252-- summary under Technical Notes Summary Under Tax Topics- Statutory Interpretation- Technical Notes Explanatory Notes not followed Lyons J applied the single supply doctrine to find that, as the University was making a single supply of education (a service) to its students, it should be considered to have acquired the books which it supplied to them at no additional charge for this “ultimate” purpose rather than for the purpose of merely transferring their ownership to the students. ...