(3)-(29)

Subsection 20(3) - Borrowed money

Cases

Brown v. The Queen, 2020 TCC 84 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) wholly-owned corporations that currently could not legally pay dividends were a source of income for s. 20(1)(c) purposes 333

The Queen v. Shore, 92 DTC 6059 (FCTD)

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Administrative Policy

2018 Ruling 2018-0740931R3 F - deductibility of interest – convertible debentures

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on borrowed money used to pay a premium on the cash redemption of convertible debentures is deductible 440

24 August 1994 Internal T.I. 9420517 - INTEREST DEDUCTIBILITY

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5 January 1993 T.I. (Tax Window, No. 28, p. 10, ¶2395)

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Subsection 20(4) - Bad debts from dispositions of depreciable property

Cases

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

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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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Administrative Policy

4 September 1991 T.I. (Tax Window, No. 10, p. 17, ¶1473)

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IT-220R2 "Capital Cost Allowance - Proceeds of Disposition of Depreciable Property" under "Bad Debts"

Subsection 20(5) - Sale of agreement for sale, mortgage or hypothecary claim included in proceeds of disposition

Administrative Policy

IT-323 "Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property"

Subsection 20(7) - Where para. (1)(m) does not apply

Paragraph 20(7)(a)

Cases

Sears Canada Inc. v. The Queen, 86 DTC 6304, [1986] 2 CTC 80 (FCTD), aff'd 89 DTC 5039 (FCA)

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Amesbury Distributors Ltd. v. The Queen, 85 DTC 5076, [1984] CTC 667 (FCTD)

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Mister Muffler Ltd. v. The Queen, 74 DTC 6615, [1974] CTC 813 (FCTD)

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See Also

Redhead Equipment Ltd. v. The Queen, 2001 DTC 429 (TCC)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) reserve for future inspection costs down adjustable based on hindsight 134

Dubawn Holdings Inc. v. The Queen, 94 DTC 1252, [1994] 1 CTC 2527 (TCC)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(e) deducted if factually deducted 81

Administrative Policy

89 C.R. - Q.21

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Subsection 20(10) - Convention expenses

Cases

See Also

Administrative Policy

6 October 2017 APFF Roundtable Q. 12, 2017-0709111C6 F - Dépenses relatives à un congrès

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training convention expenses "historically" viewed as capital expenditures 71

1 March 2013 External T.I. 2013-0477911E5 - Expenses to host employees and spouses at a resort

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30 May 2011 External T.I. 2011-0393731E5 F - Congrès

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Words and Phrases
convention

28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose expense incurred in course of operating real property need not have a direct effect on profit 386
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training distinction between training and convention expenses/luncheon seminar fees on case law generally are professional deductions 329

Articles

Novek, "Convention Expenses Are Subject to Territorial Limitations", Taxation of Executive Compensation and Retirement, February 1992, p. 557.

Subsection 20(11) - Foreign taxes on income from property exceeding 15%

Administrative Policy

31 January 2018 External T.I. 2016-0676431E5 - foreign tax credit on employees profit sharing

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Tax Topics - Income Tax Act - Section 125 - Subsection 125(1) $200 basket for NBIT for which country-by-country reporting is not required includes flow-through EPSP taxes 153
Tax Topics - Income Tax Act - Section 144 - Subsection 144(8.1) - Paragraph 144(8.1)(b) 15% limitation on FTC credit 93
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) no s. 20(12) deduction to EPSP beneficiary 108

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 133
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 169
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) s. 20(14) deduction for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 439
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 331
Tax Topics - Treaties - Income Tax Conventions - Article 24 Treaty sourcing rule does not trench on domestic FTC 215

10 June 2013 STEP CRA Roundtable, 2013-0480301C6 - 2013 STEP CRA Roundtable – Question 4

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Tax Topics - Treaties - Income Tax Conventions - Article 24 Art. 24(5) of US treaty a complete code for US citizens 117

10 June 2013 STEP Roundtable, 2013-0480371C6 - 2013 STEP Question 13 - US LLCs and 20(11)

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3 March 1997 Internal T.I. 9641327 - SUBSECTION 20(11) AND TAX TREATIES

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84 C.R. - Q.34

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IT-506 "Foreign Income Taxes as a Deduction from Income"

Articles

Tim Barrett, Kevin Duxbury, "Corporate Integration: Outbound Structuring in the United States After Tax Reform", 2018 Conference Report (Canadian Tax Foundation), 18:1-76

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Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

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Subsection 20(12) - Foreign non-business income tax

Cases

FLSmidth v. The Queen, 2013 DTC 5118 [at 6147], 2013 FCA 160, aff'g infra

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See Also

Emergis Inc. v. The Queen, 2021 TCC 23

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Words and Phrases
in respect of

FLSmidth Ltd. v. The Queen, 2012 DTC 1052 [at 2745], 2012 TCC 3, aff'd 2013 DTC 5118 [at 6147], 2013 FCA 160

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Kaiser v. MNR, 91 DTC 1057 (TCC)

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Tax Topics - Statutory Interpretation - Headings headings have higher status than marginal notes 50

Administrative Policy

29 May 2018 STEP Roundtable Q. 13, 2018-0744161C6 - 75(2) and Foreign Tax Credit

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) U.S.-dividend income attributed under s. 75(2) does not generate FTCs for the related withholding tax 181

31 January 2018 External T.I. 2016-0676431E5 - foreign tax credit on employees profit sharing

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Tax Topics - Income Tax Act - Section 125 - Subsection 125(1) $200 basket for NBIT for which country-by-country reporting is not required includes flow-through EPSP taxes 153
Tax Topics - Income Tax Act - Section 144 - Subsection 144(8.1) - Paragraph 144(8.1)(b) 15% limitation on FTC credit 93
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) no s. 20(11) deduction for foreign taxes respecting EPSP income allocated to beneficiary 107

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 133
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 169
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) only income was taxable capital gains 136
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 331
Tax Topics - Treaties - Income Tax Conventions - Article 24 Treaty sourcing rule does not trench on domestic FTC 215

15 December 2015 Internal T.I. 2014-0560371I7 - Subsection 20(12) deduction

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7 March 2016 Internal T.I. 2015-0572461I7 - Foreign tax deduction

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11 June 2013 STEP Roundtable, 2013-0480321C6 - 2013 STEP Question 6 US LLCs - FAPI, FAT and FTCs

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28 May 2013 Internal T.I. 2013-0476381I7 - Deemed Resident Trusts & Foreign Tax Credit

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain 295
Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(b) 295

18 July 2011 Internal T.I. 2011-0394631I7 - Foreign non-business income tax

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1 October 2008 T.I. 2006-0174701E5 

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22 July 2008 Internal T.I. 2008-0284351I7 - Subsection 20(12)

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Words and Phrases
paid for the year

10 January 2005 External T.I. 2004-0075931E5 - adjusted cost base - partnership interest

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19 March 2004 External T.I. 2003-0037301E5 - IRA transfer to RRSP; foreign tax credits

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10 April 2003 External T.I. 2003-0003095 - Foreign non-business income tax

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21 February 2000 T.I. 1999-0010295

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10 February 1993 Memo 9300776

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20 November 1992 T.I. 123456 (September 1993 Access Letter, p. 410, ¶C20-1160)

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October 1992 Central Region Rulings Directorate Tax Seminar, Q. J (May 1993 Access Letter, p. 231)

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25 March 1991 Memo 7-4727

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Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax US withholding on share redemption was income tax 81

88 C.R. - Q.57

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16 July 1985 Memo 7-4095

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Articles

Subsection 20(14) - Accrued bond interest

Cases

Canada v. Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25

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See Also

Mitchell v. The Queen, 96 DTC o (TCC)

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Badshah B. Husain v. Minister of National Revenue, 91 DTC 278, [1991] 1 CTC 2266 (TCC)

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Administrative Policy

27 November 2018 CTF Roundtable Q. 14, 2018-0779911C6 - Foreign exchange

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Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) - Paragraph 261(2)(b) accrued interest under both ss. 20(14)(a) and (b) is translated at the transfer date spot rate 135

92 C.R. - Q.1

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90 C.R. - Q.13

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Articles

Ewens, "Debt-for-Debt Exchanges", 1991 Canadian Tax Journal, p. 615

Ulmer, "Taxation of Interest Income", 1990 Conference Report, pp. 8:19-20

Paragraph 20(14)(a)

Articles

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27

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Subsection 20(16) - Terminal loss

Cases

May Bros. Farm Ltd. v. The Queen, 92 DTC 6342 (FCA)

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See Also

Benedict v. The Queen, 2012 DTC 1170 [at 3419], 2012 TCC 174 (Informal Procedure)

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Greater Toronto Airports Authority v. International Lease Finance Corp. (2004), 69 OR (3d) 1 (CA)

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Administrative Policy

11 June 2010 External T.I. 2010-0354881E5 F - Traitement fiscal de la FNACC

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) application of s. 45(1)(a) to film production that ceased to generate income, resulting in a terminal loss under s. 20(16) 43

93 C.P.T.J. - Q.25

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13 May 1991 T.I. (Tax Window, No. 3, p. 15, ¶1231)

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Subsection 20(16.1)

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 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

Subsection 20(21) - Debt obligation

Administrative Policy

19 March 1992 Memorandum (Tax Window, No. 18, p. 6, ¶1820)

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Articles

Ewens, "Debt-for-Debt Exchanges", 1991 Canadian Tax Journal, p. 615: Discussion of potential deduction to holders of debentures in a target corporation for arrears of interest realized under s. 76(1).

Subsection 20(24) - Amounts paid for undertaking future obligations

Administrative Policy

2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions 292
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up 297
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) continuation of s. 34.2(11) reserve following partnership wind-up 336
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up 284
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up 232
Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) s. 147.2 continuity following s. 98(5) wind-up 356
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs 347
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement - Paragraph (k) no income on RSU/DSU assumption 22

2015 Ruling 2014-0552871R3 - Split-Up Butterfly

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution post-butterfly sale of distributed shares by TC1 to TC2/disproportionate split of CDA/assumption of prepaid rent (for which a 20(24) election) treated as boot 773
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) post-butterfly sale of distributed shares by one TC to the other 63

8 December 2010 External T.I. 2010-0375921E5 - Subsection 20(24)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) deferred revenue oblgation assumption was s. 12(1)(x) income 52

2009 Ruling 2008-0304371R3 - Single-Wing Butterfly

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution net receivables and prepaids of rental company reclassified as business property 151

2008 Ruling 2008-0279671R3 - Partnership Wind-up

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7 March 2005 External T.I. 2005-0114981E5 - Subsection 20(24) of the Act

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20 November 2003 External T.I. 2003-0033545 - partnership dissolution

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continuity under s. 98(5) 80

15 November 1999 External T.I. 9924585 - PREPAID RENT&SALE OF BUILDING

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) lowering of sale price 86

June 1991 Memorandum (Tax Window, No. 4, p. 18, ¶1274)

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22 April 1991 Memorandum (Tax Window, No. 2, p. 24, ¶1192)

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5 June 1990 TI File 7-4678

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Articles

Ron Choudhury, "Non-Resident Issues in Acqusition Transactions", 2005 Conference Report (Canadian Tax Foundation), 42:9-16.

Bergen, "Purchase and Sale of Assets: An Update", 1996 Corporate Management Tax Conference Report, pp. 3:6-8.

Subsection 20(29) - Idem [Deduction before available for use]

Administrative Policy

13 April 1992 T.I. (Tax Window, No. 18, p. 13, ¶1843)

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