Section 10

Subsection 10(1) - Valuation of inventory

Cases

CDSL Canada Limited v. Canada, 2010 DTC 5055 [at 6746], 2008 FCA 400

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Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103

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Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).

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Van Dongen v. The Queen, 90 DTC 6633 (FCTD)

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The Queen v. Cyprus Anvil Mining Corp., 90 DTC 6063 (FCA)

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The Queen v. Thyssen Canada Ltd., 87 DTC 5038, [1987] 1 CTC 112 (FCA)

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The Queen v. Metropolitan Properties Co. Ltd., 85 DTC 5128, [1985] 1 CTC 169 (FCTD)

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Saskatchewan Co-Operative Credit Society Ltd. v. The Queen, 84 DTC 6225, [1984] CTC 628 (FCTD), aff'd 85 DTC 5599 [1986] 1 CTC 53 (FCA)

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Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122 (FCA)

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Rudolph Furniture Ltd. v. The Queen, 82 DTC 6196, [1982] CTC 211 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(3) 24

Minister of National Revenue v. Shofar Investment Corporation, 79 DTC 5347, [1979] CTC 433, [1980] 1 S.C.R. 350

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Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD)

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Lawson v. Minister of National Revenue, 69 DTC 5155, [1969] CTC 201, [1969] S.C.R. 587

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Irwin v. The Queen, 64 DTC 5227, [1964] CTC 362, [1968] S.C.R. 462

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MNR v. Anaconda American Brass Ltd., 55 DTC 1220, [1955] CTC 311 (PC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Accounting Principles 46

See Also

Kruger Incorporated v. The Queen, 2015 DTC 1127 [at 788], 2015 TCC 119, rev'd 2016 FCA 186

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory options contracts purchased, but not those written, were inventory 114
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) paper manufacturer's large-scale options-trading operation was a separate business 156
Tax Topics - Income Tax Act - Section 9 - Timing realization principle applied to FX options written by taxpayer 293

Grant v. The Queen, 2000 DTC 1985 (TCC) (Informal Procedure)

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General Motors Acceptance Corp. of Canada Ltd. v. The Queen, 2000 DTC 1844 (TCC)

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Ruland Realty Ltd. v. The Queen, 98 DTC 2172 (TCC), briefly aff'd 2000 DTC 6142 (FCA)

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Stein v. The Queen, 96 DTC 1526 (TCC)

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Consoltex Inc. v. The Queen, 96 DTC 1812 (TCC)

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Tax Topics - Income Tax Act - Section 9 - Accounting Principles 123

Northwood Pulp and Paper Ltd. v. The Queen, 96 DTC 1105 (TCC), aff'd 98 DTC 6640 (FCA)

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Orlando Corp. v. The Queen, 94 DTC 1046 (TCC)

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Weatherhead v. MNR, 90 DTC 1398 (TCC)

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Bailey v. MNR, 90 DTC 1321 (TCC)

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Eckel v. Board of Inland Revenue, [1989] BTC 94 (PC)

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Saskatchewan Wheat Pool v. The Queen, 85 DTC 5034, [1985] 1 CTC 30 (FCA)

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Thomson Hill Ltd. v. C.I.T. (Singapore), [1984] BTC 124 (PC)

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Lowe & Ors. v. C.I.R. (New Zealand), [1984] BTC 3 (PC)

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Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.)

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B.S.C. Footwear Ltd. v. Ridgway, [1972] A.C. 544 (HL)

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Ostime v. Duple Motor Bodies Ltd., [1961] 2 All E.R. 167 (HL)

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Resolving Ambiguity 32

Hughes v. British Burmah Petroleum Co., Ltd. (1932), 17 TC 286 (KBD)

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Administrative Policy

1 May 2018 External T.I. 2017-0709101E5 F - Travaux en cours

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(5) - Paragraph 10(5)(a) cost of professional practice WIP includes variable overheads and all related payroll costs, but not partner or shareholder-manager time 166
Tax Topics - Income Tax Act - Section 10 - Subsection 10(4) - Paragraph 10(4)(a) WIP under a contingency fee basis generally has a nil value 123

1 May 2000 Internal T.I. 1999-0010677 -

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1996 A.P.F.F. Round Table No. 7M12910 (Item 4.1.1)

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8 August 1995 Memorandum 951766 (C.T.O. "Cost of Identical Property - Inventory")

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1994 A.P.F.F. Round Table, Q. 12

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4 March 1994 T.I. 932098 (C.T.O. "Inventory")

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93 CPTJ - Q.5

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22 June 1993 T.I. (Tax Window, No. 32, p. 20, ¶2622)

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1 February 1993 T.I. (Tax Window, No. 28, p. 11, ¶2386)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit 57

10 November 1992 Memorandum (Tax Window, No. 27, p. 19, ¶2344)

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October 1992 Central Rulings Directorate Tax Seminar, Q. D (May 1993 Access Letter, p. 229)

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14 November 1991 Memorandum (Tax Window, No. 11, p. 2, ¶1534)

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89 C.M.TC - Q.19

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89 C.M.TC - Q.20

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88 C.R. - Q.50

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IT-473 "Inventory Valuation"

IT-165R "Returnable Containers"

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IT-153R3 "Land Developers - Subdivision and Development Costs and Carrying Charges on Land"

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Subsection 10(1.01) - Adventures in the nature of trade

See Also

Stremler v. The Queen, 2000 DTC 1757 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Estoppel 65

Administrative Policy

24 May 2013 External T.I. 2013-0487581E5 F - Nature d'un bien acquis pour la revente

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Words and Phrases
cost

Subsection 10(1.1) - Certain expenses included in cost

Administrative Policy

17 October 1997 T.I. 970738

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1996 A.P.F.F. Round Table, Q. 4.1 (9630450)

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89 C.R. - Q.45

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Subsection 10(2) - Continuation of valuation

Cases

The Queen v. Boehringer Ingelheim (Canada) Ltd., 85 DTC 5443, [1985] 2 CTC 211 (FCTD), aff'd 87 DTC 5442, [1987] 2 CTC 245 (FCA)

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Cyprus Anvil Mining Corp. v. The Queen, 85 DTC 5306, [1985] 2 CTC 74 (FCTD), rev'd 90 DTC 6063 (FCA) [by the reasons for judgment of Urie J.A., but not by those of Hugessen J.A.]

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Quebec North Shore Paper Co. v. The Queen, 78 DTC 6426, [1978] CTC 628 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 42

Administrative Policy

29 May 2017 External T.I. 2014-0537111E5 F - Consequential assessment

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.3) reassessing to increase closing inventory permits a s. 152(4.3) reassessment to change the taxes payable "balance" for the following year 129

Articles

David A. Ward, "Attribution of Income to Permanent Establishments", Canadian Tax Journal, Vol. 48, No. 3, 2000, p. 559.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 7 0

Subsection 10(3) - Incorrect valuation

Cases

Rudolph Furniture Ltd. v. The Queen, 82 DTC 6196, [1982] CTC 211 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) 119

Subsection 10(4)

Paragraph 10(4)(a)

Administrative Policy

1 May 2018 External T.I. 2017-0709101E5 F - Travaux en cours

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(5) - Paragraph 10(5)(a) cost of professional practice WIP includes variable overheads and all related payroll costs, but not partner or shareholder-manager time 166
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) professionals' WIP excludes partner time but includes variable overhead 137

Subsection 10(5) - Inventory

Cases

Administrative Policy

IT-51R2 "Supplies On Hand at the End of a Fiscal Period"

IT-457R "Election by Professionals to Exclude Work in Progress from Income" under "Meaning of 'Work in Progress'"

Paragraph 10(5)(a)

Administrative Policy

1 May 2018 External T.I. 2017-0709101E5 F - Travaux en cours

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 10 - Subsection 10(4) - Paragraph 10(4)(a) WIP under a contingency fee basis generally has a nil value 123
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) professionals' WIP excludes partner time but includes variable overhead 137

Billed-basis Accounting (CRA Webpage) 28 April 2017

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Articles

Joint Committee, "Proposed Amendments to Taxation of Work in Progress ("WIP") for Professionals", Letter of 31 May 2017

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Tax Topics - Income Tax Act - Section 34 deferral enjoyed by previous partners reversed in hands of current partners 60

Subsection 10(6) - Artistic endeavour

Administrative Policy

19 May 1994 External T.I. 3-940875

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Subsection 10(14.1)

Administrative Policy

26 March 2018 External T.I. 2017-0734381E5 F - Election paragraph 34(a)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 34 a subsequently admitted partner benefits from a s. 34 WIP election made for a professional partnership’s 2017 year 160