Section 14

Subsection 14(1) - Eligible capital property — inclusion in income from business

Administrative Policy

6 June 1994 External T.I. 9337165 - GOODWILL

Where on the sale of the business of a partnership of three equal partners (two individuals and a corporation), $360,000 is received for goodwill...

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26 September 89 T.I. (February 1990 Access Letter, ¶1098)

A taxable capital gain pursuant to s. 14(1)(a)(v) is not considered business income, and therefore does not constitute earned income for purposes...

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Finance

29 July 2019 Finance Comfort Letter respecting Eligible Capital Property (ECP) Transitional Issue

A CCPC disposed of eligible capital property (ECP) before the Budget 2016 date, but with part of the proceeds not becoming receivable until after...

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Articles

Alison Spiers, "ECP Planning: Some Practical Considerations", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p 1

Given a judicial view that goodwill is inseparable from the business to which it adds value, it would appear that the accrued gain on goodwill...

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Paragraph 14(1)(a)

Administrative Policy

6 May 2005 External T.I. 2005-0116981E5 F - Rollover under section 85 of an ECP

Mr. X made an election under s. 110.6(19) in respect of his trading business carried on, on February 22, 1994, and, as a consequence, had an...

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Paragraph 14(1)(b)

Administrative Policy

7 October 2005 Roundtable, 2005-0140891C6 F - Disposition d'une immobilisation

Opco transferred business assets, including goodwill with a nil CEC and a $1 million FMV to a new subsidiary ("Newco"). The proceeds of...

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Subsection 14(1.01)

Administrative Policy

9 November 2005 Internal T.I. 2005-0154301I7 F - Choix concernant les immobilisations admissibles

On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec...

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 operating agreement of care facility with province was goodwill because it could not be transferred without a transfer of the care business 232

9 June 2005 Internal T.I. 2005-0117851I7 F - Choix du paragraphe 14(1.01) de la Loi

The Directorate indicated that an election under s. 14(1.01) could not be made where the gain on the disposition of eligible capital property was...

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Subsection 14(3) - Acquisition of eligible capital property

Administrative Policy

27 October 2006 External T.I. 2006-0212001E5 F - Immobilisations admissibles - Quotas

In addition to having acquired 45,300 chicken quota units from its shareholders (so as to engage a basis grind under s. 14(3) because it did not...

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15 January 1996 External T.I. 9527995 - REVERSAL OF REDUCTION IN ECE

Where an eligible capital property has been transferred by a taxpayer ("A") to a non-arm's length person ("B"), the grind to B under s. 14(3)...

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Subsection 14(5) - Definitions

Cumulative Eligible Capital

Cases

RCI Environnement Inc. v. Canada, 2009 DTC 5940, 2008 FCA 419

A lump sum received by the taxpayer in consideration for the cancellation of a non-competition agreement that it previously had received in...

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Canada v. Toronto Refiners and Smelters Ltd., 2003 DTC 5002, 2002 FCA 476

The taxpayer received pursuant to the Expropriation Act (Ontario) $3 million in respect of the acquisition of its land and building by the City of...

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Words and Phrases
consideration

Teleglobe Canada Inc. v. R., 2002 DTC 7517, 2002 FCA 408

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...

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Locations of other summaries Wordcount
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 207

Pe Ben Industries Co. Ltd. v. The Queen, 88 DTC 6347, [1988] 2 CTC 120 (FCTD)

A payment made by Northern Alberta Railway ("NAR") to the taxpayer as compensation to the taxpayer for the termination by NAR of a major contract...

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The Queen v. Goodwin Johnson (1960) Ltd., 86 DTC 6185, [1986] 1 CTC 448 (FCA)

The sum of $830,000 received by the taxpayer, which had been the manager of a logging operation, in settlement of its action for termination of...

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The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA)

Mahoney, J. stated that a definition of the goodwill of a private hospital "should bear in mind that the basis of its worth was its power to...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 68 54

Samoth Financial Corp. Ltd. v. The Queen, 85 DTC 5473, [1985] 2 CTC 275 (FCTD), aff'd 86 DTC 6335, [1986] 2 CTC (FCA)

The plaintiff, which purchased the exclusive right to sell Century 21 franchises to licensed real estate brokers, was found to be in the business...

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The Queen v. Leopold Lague Ltd., 82 DTC 6310, [1981] CTC 348 (FCTD)

The assignment by a school bus operator of a 3-year contract with a school board constituted the disposition of an eligible capital property...

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The Queen v. Timagami Financial Services Ltd., 82 DTC 6268, [1982] CTC 314 (FCA)

Where the consideration for sale of goodwill is to be paid to the vendor over a series of years, then 1/2 of the amounts so paid are included as...

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Words and Phrases
payable

Pepsi-Cola Canada Ltd. v. The Queen, 79 DTC 5387, [1979] CTC 454 (FCA)

A payment of $100,000 made to the taxpayer upon the termination of an agreement between the taxpayer and Schwepps Powell Ltd. under which the...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 43

See Also

Henco Industries Limited v. The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192

A subdivision property of the taxpayer, a developer, was blockaded by Six Nations protesters. To diffuse the conflict, the Ontario government...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence parol evidence rule not applying to surrounding evidence/press releases admitted 239
Tax Topics - General Concepts - Fair Market Value - Land deference to taxpayer's figure within appraiser's range of values 111
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) compensation received in course of business but not in course of earning income 192
Tax Topics - Income Tax Act - Section 23 - Subsection 23(1) land ceased to be inventory through sterilization rather than business cessation 184
Tax Topics - Income Tax Act - Section 3 compensation payment for destroyed business was non-taxable 171
Tax Topics - Income Tax Act - Section 9 - Compensation Payments compensation payment for destroyed business was non-taxable 171

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)

The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). DCUK exercised its rights under its dealer agreements to...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 167.1 326

Winsor v. The Queen, 2008 DTC 2116, 2007 TCC 692

An amount received by the taxpayer from the federal government as compensation for the cancellation by the federal government of his fishing...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property fishing licence was property based on administrative law rights 92
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Leases and Licences 28

Fortino v. The Queen, 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)

Amounts received by the individual vendors of shares for entering into a non-compete covenant with the purchaser did not represent eligible...

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Les Placements A & N Robitaille Inc. v. MNR, 96 DTC 1062, [1996] 1 CTC 2141 (TCC)

Archambault TCJ. found that a business of manufacturing or reconditioning and selling boats or other nautical products had goodwill that was not...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Other 74

Consumers Software Inc. v. The Queen, 95 DTC 518, [1993] 2 CTC 3129 (TCC) (Informal Procedure)

Proceeds received by the taxpayer from the sale of a software program (coupled with the granting of a non-compete covenant but with the retention...

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Administrative Policy

12 January 2015 External T.I. 2014-0555071E5 - POD subject to earn-out

In an arm's length sale the corporate "Vendor" disposes of the "Property" (including land options agreements, permits, engineering data and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) proceeds of goodwill on sale of wind turbine development project 201
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Cumulative Canadian exploration expense - Element G proceeds of wind turbine development project 147
Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) wind turbine development project 108

9 February 2015 External T.I. 2013-0480881E5 F - Disposition of Eligible Funeral Arrangement Contracts

Amounts received on the sale of a funeral home business which are allocated to prepaid funeral contracts or other "eligible funeral arrangements"...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148.1 - Subsection 148.1(2) - Paragraph 148.1(2)(b) proceeds on disposition of funeral home business 267

23 May 2014 External T.I. 2014-0518921E5 F - Calcul de l'élément A du MCIA

In 2008 a taxpayer with nil cumulative eligible capital disposed of the assets of an active business including goodwill to a related corporation...

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29 October 2013 External T.I. 2013-0489911E5 - Disposition of CRCE intangibles

A developer of an electricity generation project transfers the related contracts and development work (the "Intangible Expenditures") to another...

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27 January 2011 External T.I. 2010-0380081E5 - Trailing commissions

In response to a query as to whether a payment received for the transfer of brokerage clients in respect of whom trailer commissions were being...

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17 February 1995 Ministerial Correspondence 9503794 - RETIREMENT OF FISHING LICENCES

Any payment made to a fisherman to retire a fishing licence or other right or privilege to commercially fish is an eligible capital amount.

11 January 1995 Internal T.I. 9402947 - RETIRING FISHING LICENSES

Payments received by fishermen under a compensation program to retire or decrease their fishing rights represent eligible capital amounts under...

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30 March 1994 Internal T.I. 9407577 - PLAYER CONTRACTS - PROCEEDS OF DISPOSITION

Proceeds received by the vendors on the sale of a sports team in respect of players' contracts will not be eligible capital amounts because the...

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17 January 1991 Internal T.I. 7-90326

Damages paid by a principal business corporation to an investor limited partnership including amounts in respect of interest assessed against the...

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Element A.1

Administrative Policy

22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital

A return-of-capital distribution by the foreign affiliate of a Canadian corporation of eligible capital property (in this case, intellectual...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) FMV cost of property acquired on QROC distribution 121
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) FMV cost of property acquired on contribution of capital 121
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base FMV cost of contributed or distributed property 53
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure QROC distribution by a foreign affiliate to its Canadian shareholder of ECP results in ECE to the shareholder of the property’s FMV 220

21 September 2004 External T.I. 2004-0067881E5 F - MCIA- lien de dépendance

Regarding the introduction of Element A.1 in legislative proposals regarding the CEC definition first proposed on December 20, 2002, CRA stated:...

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Element E

See Also

7958501 Canada Inc. v. Agence du revenu du Québec, 2020 QCCQ 2424, aff'd 2022 QCCA 315

A private company (“SherWeb”), which provided the use of software developed by it to paying subscribers, transferred its software and other IP...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) software whose development was deducted under s. 37 could be stepped up on a related-party transfer notwithstanding s. 13(7)(e) 476
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(d) s. 37 claims in developing software precluded it from being depreciable property 179

Administrative Policy

11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt

Rather than issuing fresh notes, a company obtained the noteholders’ agreement to extend the current notes’ maturity, and received a premium...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) denied interest expense where a premium was received on extending notes’ maturity 175

Eligible Capital Expenditure

Cases

Brooke Bond Foods Ltd. v. The Queen, 84 DTC 6144, [1984] CTC 115 (FCTD)

Amounts expended for plans and specifications of a building that ultimately was not constructed were expended for the purpose of creating a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(dd) suitability of site had already been established 35

The Queen v. Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)

In an underwriting agreement, the taxpayer agreed to issue common shares to the underwriter at $8.00 per share and pay an underwriting commission...

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See Also

Devon Canada Corporation v. The Queen, 2018 TCC 170

Two public-company predecessors by amalgamation of the taxpayer made cash payments for the surrender by employees of their options previously...

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) quaere whether “sale” includes a sale to a 3rd party 177
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) stock option surrender payments of target deductible under s. 111(5.2) 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition of surrendered stock options occurred under doctrine of merger 318
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base "cost" implies the acquisition of an asset 172

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, aff'd 2018 FCA 124

The taxpayer (“Alcan”) incurred various investment dealer, legal and other fees in connection with its successful hostile bid for most of the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 417
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible 529
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 182
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 102
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 246
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 139
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) expenses incurred in butterfly spin-off recognized as disposition expenses 63
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 108

Potash Corporation of Saskatchewan Inc. v. The Queen, 2011 DTC 1163 [at 873], 2011 TCC 213

The taxpayer incurred legal and accounting fees in 1997 and 1998 of approximately $1.9 million in connection with a complicated reorganization of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees improved tax efficiency was enduring (3 year) benefit 232

Martin v. The Queen, 2009 DTC 1251, 2009 TCC 152 (Informal Procedure)

"Commissions" paid by the taxpayer (a chartered accountant) generally over the course of several months to the former owners of accounting...

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Graham Construction Engineering (1985) Ltd. v. The Queen, 97 DTC 342 (TCC)

Professional fees incurred in connection with a share reorganization of the taxpayer in which its shareholders transferred their shares to a...

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212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)

Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for...

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The Queen v. de Loppinot, 78 DTC 6477, [1978] CTC 705 (FCTD)

An agreement between a retiring chartered accountant ("Peloquin") and a firm of chartered accountants - wherein the firm agreed to pay Peloquin...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 97

Administrative Policy

14 March 2016 Internal T.I. 2015-0609671I7 - Earnout, Amalgamation, Cost of Shares and ECE

A Canadian Acquisitionco acquired Canadian Targetco for a cash base price plus earnout obligations, and then immediately merged with Targetco...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) post-amalgamation earnout payment could be applied to increase an s. 88(1)(d) bump of capital property (but not ECP) of the amalgamated target 317
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base earnout payments an addition to cost of shares which had since disappeared 90
Tax Topics - General Concepts - Purpose/Intention attribution of predecessor's intention to Amalco 140
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) position on interest deductibility following target amalgamation is based on policy and ITA scheme rather than technical 350

22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital

What is the cost (and amount incurred as an expense) for intellectual property with an unlimited life acquired by a corporation resident in Canada...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) FMV cost of property acquired on QROC distribution 121
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) FMV cost of property acquired on contribution of capital 121
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base FMV cost of contributed or distributed property 53
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element A.1 no gain to FA transferor of ECP 99

30 July 2015 External T.I. 2014-0552041E5 F - Permis XXXXXXXXXX

CRA found that a government licence which could be renewed each year on the payment of a fee was an eligible capital property rather than a Class...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14 renewable government licences were ECP, not Class 14 202

27 June 2014 External T.I. 2014-0526931E5 F - Vente d'une liste de clients par un employé

An employer agrees to purchase the customer list of an employee prior to his cessation of employment. CRA stated (TaxInterpretations...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(e) payment to departing employee for customer list was deemed income under s. 6(3) 113

29 October 2013 External T.I. 2013-0507121E5 - Website costs

Determining whether website costs are in the nature of income or capital should entail an analysis of each component of the site. The...

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31 March 2011 Internal T.I. 2011-0291701I7

Expenses incurred by a public corporation with respect to an unsuccessful bid to acquire a public company were capital expenditures which...

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12 June 2003 Internal T.I. 2003-001100

As a result of selling a business the taxpayer was no longer able to fulfill its obligations under a supply contract and negotiated a termination...

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5 March 2003 External T.I. 2002-0151405 - Transaction Costs - Aborted Acquisition

Respecting the question whether various fees incurred by a taxable Canadian corporation with respect to the proposed acquisition of another...

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18 February 2002 External T.I. 2002-01883

In a Canadian asset acquisition by a Canadian corporation ("Buyco"), $20 of the total $200 purchase price is allocated to pension surplus. CCRA...

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1 March 2001 External T.I. 2001-0068715 - Expenses incurred aborted debt offering

Expenses incurred by a taxpayer with respect to an aborted debt offering where there was no substituted transaction would qualify as eligible...

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7 February 1992 TI (Tax Window, No. 16, p. 19, ¶1739)

The proceeds of sale of a sports franchise would be an eligible capital amount to the vendor and an eligible capital expenditure to the purchaser.

28 March 1991 Memorandum (Tax Window, No. 2, p. 25, ¶1186)

Costs incurred by an oil or gas company to acquire an easement to build a pipeline or to acquire a right of way to build a road are eligible...

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Subsection 14(7) - Replacement property

Administrative Policy

17 April 2012 External T.I. 2011-0427411E5 F - Bien de remplacement-immobilisation admissible

Where the taxpayer sells his business including client lists, purchased shares of a corporation carrying on a similar business will not qualify as...

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Subsection 14(15) - Beginning to use property in Canadian business

Articles

Orest Moysey, Stan Mag, "New Canadian Branch Making Rules for Foreign Banks: Opportunities and Issues", International Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 6, p. 1869.