Subsection 13(21) - Definitions

Depreciable Property

Cases

C.A.E. Inc. v. Canada, 2013 DTC 5084 [at 5944], 2013 FCA 92

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Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)

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The Queen v. Construction Bérou Inc. (formerly Fortin & Moreau Inc.), 96 DTC 6177, 98 DTC 6401 (FCTD), rev'd 99 DTC 5841 (FCA)

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Kettle River Sawmills Ltd. v. The Queen, 92 DTC 6525 (FCTD)

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Tax Topics - General Concepts - Effective Date 35

Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 58

Kirsch Construction Ltd. v. The Queen, 88 DTC 6503, [1988] 2 CTC 338 (FCTD)

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Alberta Oil Sands Pipeline Ltd. v. The Queen, 88 DTC 6059, [1988] 1 CTC 99 (FCTD)

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The Queen v. Henuset Bros. Ltd. [No. 1], 77 DTC 5169, [1977] CTC 227 (FCTD)

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The Queen v. Kimmel, 76 DTC 6259, [1976] CTC 443 (FCTD)

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Tax Topics - Statutory Interpretation - Reciprocity 42

The Queen v. Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD)

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Tax Topics - Statutory Interpretation - Provincial Law 57

See Also

Garber v. The Queen, 2014 DTC 1045 [at 2812], 2014 TCC 1

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Good Equipment Limited v. The Queen, 2008 DTC 2527, 2008 TCC 28

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Tax Topics - Statutory Interpretation - Provincial Law 86

Gordon v. The Queen, 95 DTC 493 (TCC)

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Words and Phrases
tangible

Re Cronin Fire Equipment Ltd. (1993), 14 OR (3d) 269 (Ont. Ct. (G.D))

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Laurent Goulet & Fils Inc. v. MNR, 92 DTC 1611 (TCC)

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Location Gaétan Lévesque Inc. v. MNR, 91 DTC 1380 (TCC)

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Words and Phrases
property property acquired
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Tax Topics - General Concepts - Ownership 111

Westcon Engineering and Contractors Ltd. v. MNR, 77 DTC 284 (T.R.B.)

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C.R. Stewart Equipment Ltd. v. MNR, 77 DTC 176 (T.R.B.)

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Chibougamau Lumber Limitée v. MNR, 73 DTC 134 (T.R.B.)

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Marine Midland Bank v. U.S., 687 F (2d) 395, 231 Ct. Cl. 496

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Helby v. Matthews, [1895] A.C. 471 (HL)

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Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

20 April 2009 External T.I. 2008-0303651E5 - Tax Implications of Leasing Arrangements

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IT-464R, para. 3

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27 January 2003 Internal T.I. 2002-017767 -

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7 February 2014 External T.I. 2014-0516921E5 F - Crédit et frais résiduels

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) employer potentially can choose to prorate terminal credits or deficiencies (based on sale price on car lease termination relative to residual value) in applying formula 246
Tax Topics - General Concepts - Substance lease characterized as lease unless its actual legal effects differ 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A lease under which lessee bore all risk implicitly treated as lease rather than purchase 171

Income Tax Technical News, No. 5, 28 July 1995

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93 C.P.T.J. - Q.20

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30 December 1992 T.I. (Tax Window, No. 27, p. 6, ¶2322)

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IT-441 "Capital Cost Allowance - Certified Feature Productions and Certified Short Productions"

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90 C.R. - Q.16

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88 C.R. - "Finance and Leasing" - "Leasing"

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Articles

Gillespie, "Lease Financing", 1992 Corporate Management Tax Conference, c. 7

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Disposition of Property

Cases

Hewlett Packard (Canada) Ltd. v. Canada, 2004 DTC 6498, 2004 FCA 240

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Tax Topics - Statutory Interpretation - Provincial Law 83

Borstad Welding Supplies (1972) Ltd. v. The Queen, 93 DTC 5457 (FCTD)

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The Queen v. Browning Harvey Ltd., 90 DTC 6105 (FCTD)

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Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (FCA)

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Olympia and York Developments Ltd. v. The Queen, 80 DTC 6184, [1980] CTC 265 (FCTD)

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Tax Topics - Income Tax Act - Section 9 - Timing 76

R. v. Malloney’s Studio Ltd., 79 DTC 5124, [1979] CTC 206, [1979] 2 S.C.R. 326

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See Also

Ipsco Inc. v. The Queen, 2002 DTC 1421 (TCC)

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Robert Bédard Auto Ltée. v. MNR, 85 DTC 643 (TCC)

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Tax Topics - General Concepts - Effective Date 152

Freesman v. The Queen, [1982] 2 F.C. 900 (T.D.)

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The Queen v. Cie Imm. BCN Ltée, 79 DTC 5068, [1979] CTC 71, [1979] 1 S.C.R. 865

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Words and Phrases
dispose

Picadilly Hotels Ltd. v. The Queen, 78 DTC 6444, [1978] CTC 658 (FCTD)

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Administrative Policy

7 February 2013 External T.I. 2012-0436781E5 - Tax Treatment of Payment Received from Co-Tenant

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2 December 1992 Memorandum (Tax Window, No. 27, p. 20, ¶2349, October 1993 Access Letter, p. 480)

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92 C.R. - Q.40

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26 February 1992 T.I. (Tax Window, No. 17, p. 6, ¶1765)

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Proceeds of Disposition

Cases

Daishowa‑Marubeni International Ltd. v. Canada, 2013 DTC 5085 [at 5959], 2013 SCC 29, [2013] 2 S.C.R. 336

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Tax Topics - Statutory Interpretation - Symmetry harmonious, symmetrical scheme to be favoured 69

Brill v. The Queen, 96 DTC 6572 (FCA)

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The Queen v. Mohawk Oil Co. Ltd., 92 DTC 6135 (FCA)

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Tax Topics - Other Legislation/Constitution - Federal - Federal Court Rules - Rule 420 [Amendment of Pleadings] 32
Tax Topics - Income Tax Act - Section 9 - Compensation Payments damages received both for breach re depreciable property and lost profits 68

Avril Holdings Ltd. v. Minister of National Revenue, 70 DTC 6366, [1970] CTC 572, [1971] S.C.R. 601

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Belle-Isle v. MNR, 64 DTC 5041 (Ex Ct), briefly aff'd 66 DTC 5100, [1966] R.C.S. 354

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(4) 78

See Also

Hewlett Packard (Canada) Ltd. v. The Queen, 2003 DTC 1324 (TCC), rev'd 2004 DTC 6498, 2004 FCA 240

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Tax Topics - General Concepts - Evidence 99
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) taking assets out of use not sufficient trigger 139

Kamsel Leasing Inc. v. MNR, 93 DTC 250 (TCC)

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Tax Topics - General Concepts - Evidence 74

Tri-Star Leasing (London) Inc. v. MNR, 92 DTC 1786 (TCC)

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Tax Topics - General Concepts - Ownership 132

Robert v. MNR, 90 DTC 1281 (TCC)

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Terry v. MNR, 74 DTC 6017, [1973] CTC 837 (FCA)

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Ages v. MNR, 71 DTC 86 (TAB)

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Tax Topics - Income Tax Act - Section 9 - Nature of Income 138

Schouten v. MNR, 63 DTC 397 (TAB)

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Tax Topics - General Concepts - Evidence 30

Marcotte v. MNR, 60 DTC 519 (TAB)

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Foster v. M.N.R, 51 DTC 232 (ITAB)

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Tax Topics - General Concepts - Substance 34

Administrative Policy

29 September 1994 Memorandum 941976 (C.T.O. "Proceeds of Disposition")

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93 C.R. - Q. 42

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Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 49

Paragraph (c)

Cases

R. v. Malloney’s Studio Ltd., 79 DTC 5124, [1979] CTC 206, [1979] 2 S.C.R. 326

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Zeal and Gold Ltd. v. MNR, 73 DTC 5116, [1973] CTC 129 (FCTD)

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Paragraph (e)

Cases

Ipsco Inc. v. The Queen, 2002 DTC 1421 (TCC)

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Timber Resource Property

Cases

Itt Industries of Canada Ltd. v. Canada, 2000 DTC 6445 (FCA)

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Tax Topics - General Concepts - Stare Decisis 94

The Queen v. The Queen v. Kettle River Sawmills Ltd., 94 DTC 6086 (FCA)

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Administrative Policy

6 February 2018 External T.I. 2017-0732151E5 - Timber Resource Property

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8 April 1991 Memorandum (Tax Window, No. 4, p. 16, ¶1273)

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Undepreciated Capital Cost

A

Cases

Water's Edge Village Estates (Phase II) Ltd. v. Canada, 2002 DTC 7172, 2002 FCA 291

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 254 - Subsection 254(4) 167
Tax Topics - Income Tax Act - Section 96 exploiting modest business asset was sufficient partnership activity 221
Tax Topics - Statutory Interpretation - Resolving Ambiguity 171
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(3) prompt amendment evidenced intent to end anomaly 82

Fletcher Challenge Canada Ltd. v. The Queen, 2000 DTC 6437 (FCA)

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Tax Topics - Income Tax Application Rules - Subsection 20(1) 97

Canada v. Construction Bérou Inc., 99 D.T.C 5869 (FCA)

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Alberta Wheat Pool v. Canada, 99 DTC 5198 (FCA)

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Tax Topics - Income Tax Act - Section 21 - Subsection 21(1) 133

The Queen v. The Queen v. Kettle River Sawmills Ltd., 94 DTC 6086 (FCA)

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Newfoundland Light & Power Co. Ltd. v. The Queen, 90 DTC 6166 (FCA)

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Hazlewood v. The Queen, 89 DTC 5537 (FCTD)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 62

Edmonton Plaza Hotel (1980) Ltd. v. The Queen, 87 DTC 5371, [1987] 2 CTC 153 (FCTD)

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Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (FCA)

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The Queen v. Gelber, 83 DTC 5385, [1983] CTC 381 (FCA)

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Tax Topics - Income Tax Act - Section 245 - Old 107

Roywood Investments Ltd. v. The Queen, 81 DTC 5148, [1981] CTC 206 (FCA)

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Bomag (Canada) Ltd. v. The Queen, 81 DTC 5085, [1981] CTC 156 (FCTD), aff'd 84 DTC 6363, [1984] CTC 378 (FCA)

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Shabro Investments Ltd. v. The Queen, 79 DTC 5104, [1979] CTC 125 (FCA)

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Lipper v. The Queen, 79 DTC 5246, [1979] CTC 316 (FCTD)

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Mandel v. The Queen, 78 DTC 6518, [1978] CTC 780 (FCA), briefly aff'd 80 DTC 6148, [1980] CTC 130, [1980] 1 S.C.R. 318

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Words and Phrases
contingent liability

McKee v. The Queen, 77 DTC 5345, [1977] CTC 491 (FCTD)

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Simard-Beaudry Inc. v. M.N.R., 74 DTC 6552, [1974] CTC 715 (FCTD)

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Tax Topics - General Concepts - Agency 47
Tax Topics - General Concepts - Sham motives should not be exaggerated 90
Tax Topics - General Concepts - Tax Avoidance motives should not be exaggerated 90
Tax Topics - Income Tax Act - Section 245 - Old 130

Elias Rogers Co Ltd. v. MNR, 73 DTC 5030, [1972] CTC 601 (FCTD)

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MNR v. Wardean Drilling Ltd., 69 DTC 5194 (Ex Ct)

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Weinberger v. MNR, 64 DTC 5060 (Ex Ct)

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See Also

Berhad v. Director General of Inland Revenue, [1985] BTC 578 (PC)

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Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 46

The Queen v. Yelle, 2010 DTC 5128 [at 7083], 2010 ABPC 94

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On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at 4243], 2010 TCC 475

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Tax Topics - General Concepts - Evidence parol evidence rule applied to Minister 106
Tax Topics - Income Tax Act - Section 9 - Nature of Income 117

Sherman v. The Queen, 2008 DTC 3069, 2008 TCC 186, aff'd 2009 DTC 5681, 2009 FCA 9

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Andrews v. The Queen, 2007 DTC 901, 2007 TCC 312 (Informal Procedure)

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Tax Topics - General Concepts - Ownership 87

A & D Holdings Inc. v.The Queen, 2006 DTC 2219, 2005 TCC 768

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Terexcavation Antoine Grant Inc. v. The Queen, 2005 DTC 709 (TCC)

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Morley v. The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171

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Brown v. The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA)

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Sun Life Assurance Co. of Canada v. The Queen, 97 DTC 422 (TCC)

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Cadillac Fairview Corp. Ltd. v. The Queen, 97 DTC 405 (TCC)

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Words and Phrases
land
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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 3 obtaining density for building expansion was land cost rather than Class 3 cost 98

Wharf Properties Ltd. v. Commissioner of Inland Revenue (Hong Kong), [1997] BTC 173 (PC)

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Gartry v. The Queen, 94 DTC 1947 (TCC)

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Harvey v. The Queen, 94 DTC 1910 (TCC)

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Gold Line Transport Ltd. v. MNR, 92 DTC 2005 (TCC)

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The Queen v. Canadian Pacific Ltd., 77 DTC 5383, [1977] CTC 606 (FCA)

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Denison Mines Ltd. v. Minister of National Revenue, 74 DTC 6525, [1974] CTC 737, [1976] 1 S.C.R. 245

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Cockshutt Farm Equipment of Canada Ltd. v. MNR, 66 DTC 544, 41 Tax A.B.C. 386

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6 October 2017 APFF Roundtable Q. 7, 2017-0709051C6 F - Dédommagement-annulation d'une offre d'achat

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Tax Topics - Income Tax Act - Section 54 - Capital Property damages for breach of a purchaser's covenant were proceeds of a capital property 158

S3-F4-C1 - General Discussion of Capital Cost Allowance

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) use of manufacturer’s electricity-use standard 88
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A installation cost included 31
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease 249
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) vehicle assistance paid indirectly (to dealer) covered 225

7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) use of manufacturer’s electricity-use standard 88
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease 249
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) vehicle assistance paid indirectly (to dealer) covered 225
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost not reduced under general principles by government assistance 137

7 February 2014 External T.I. 2014-0516921E5 F - Crédit et frais résiduels

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property lease/sale distinction established based on the legal relationship 93
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) employer potentially can choose to prorate terminal credits or deficiencies (based on sale price on car lease termination relative to residual value) in applying formula 246
Tax Topics - General Concepts - Substance lease characterized as lease unless its actual legal effects differ 142

27 August 2012 External T.I. 2012-0438741E5 - Deductibility of Lease Payments

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16 December 2003 External T.I. 2002-013366 -

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2001 Ruling 2000-003987 -

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) compensation for assuming contingent liabilities 29

20 January 1999 T.I. 983230

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Tax Topics - General Concepts - Substance 38

17 April 1998 External T.I. 5-972078 -

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10 February 1997 Internal T.I. 7-970127 -

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9 June 1995 External T.I. 5-951145 -

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14 August 1992 T.I. 921331 (May 1993 Access Letter, p. 192, ¶C20-070)

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10 January 1991 Memorandum (Tax Window, Prelim. No. 3, p. 31, ¶1084)

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89 C.M.TC - "Capitalization of Soft Costs - Buildings under Construction" - "Types of Costs to which Subsection 18(3.1) Applies

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84 C.R. - Q.74

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81 CR - Q.23

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IT-441 dated November 29, 1979 "Capital Cost Allowance - Certified Feature Productions and Certified Short Productions"

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IT-464R "Capital Cost Allowance - Leasehold Interest"

IT-477, para. 20

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E

See Also

Envision Credit Union v. The Queen, 2010 DTC 1399 [at 4585], 2010 TCC 576, aff'd 2012 DTC 5055 [at 6842], 2011 FCA 321, aff'd 2013 DTC 5144 [at 6275], 2013 SCC 48

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29 July 2015 Internal T.I. 2015-0575921I7 - Recapture arising in statute-barred years

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) negative UCC balance arising in statute-barred year becomes recapture in 1st open year 438
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) negative UCC balance arising in statute-barred year becomes recapture in 1st open year 143

F

See Also

Duncan v. The Queen, 2001 DTC 96 (TCC)

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Tax Topics - Income Tax Act - Section 96 155

Wang Canada Ltd. v. MNR, 91 DTC 1279 (TCC)

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7 April 2005 External T.I. 2005-0109721E5 - GST Penalty in a Wash Transaction

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G

Cases

Canterra Energy Ltd. v. The Queen, 85 DTC 5245, [1985] 1 CTC 329 (FCTD), rev'd 87 DTC 5019, [1987] 1 CTC 89 (FCA)

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Paragraph 13(21)(e)

See Also

Alberta Power (2000) Ltd. v. The Queen, 2009 DTC 1514, 2009 TCC 412

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Tax Topics - General Concepts - Ownership 54
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) definition of "reimbursement;" exclusion for legal obligation from legitimate negotiations 216
Tax Topics - Income Tax Act - Section 9 - Compensation Payments amount was received in respect of impaired capital asset (which then was transferred to payor) rather than for lost profits 107