Section 16

Subsection 16(1) - Income and capital combined

Cases

Plains Midstream Canada ULC v. Canada, 2019 FCA 57

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest by its nature is symmetrical 237

The Queen v. Shaw, 93 DTC 5121 (C.A.)

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West Hill Redevelopment Co. Ltd. v. The Queen, 91 DTC 5430 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) mortgages included in proceeds at their principal amount rather than lower FMV 53
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory 42

Alepin v. The Queen, 79 DTC 5259 (FCTD)

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Rodman Construction Inc. v. The Queen, 75 DTC 5038, [1975] CTC 73 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 75

Vanwest Logging Co. Ltd. v. MNR, 71 DTC 5120 (Ex Ct)

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Groulx v. MNR, 67 DTC 5284, [1967] CTC 422, [1968] R.C.S. 6

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MNR v. Mandelbaum, 62 DTC 1093 (Ex Ct)

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See Also

Plains Midstream Canada ULC v. The Queen, 2017 TCC 207, aff'd 2019 FCA 57

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base ACB addition based on future amount payable rather than much lower FMV 221

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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Lehigh Cement Limited v. The Queen, 2009 DTC 776, 2009 TCC 237, rev'd 2010 DTC 6844, 2010 FCA 124

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Gestion Guy Ménard Inc. v. MNR, 93 DTC 1058 (TCC)

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O'Neil v. MNR, 91 DTC 692 (TCC)

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Administrative Policy

18 April 2013 Internal T.I. 2013-0485481I7 F - Balance of sale price without interest

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9 September 2002 Internal T.I. 2002-014900 -

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IT-233R "Lease-Option Agreement; Sale-Lease Back Agreements"

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3 December 1992 T.I. 921655 (C.T.O. "Factoring Accounts Receivable Whether Sale or Loan"; Tax Window, No. 26, p. 5, ¶2315)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) - Subparagraph 212(1)(b)(i) non-arm’s length terms on sale of trade receivables to sub would indicate that it in fact was a non-arm’s length loan 312

IT-265R3 "Payments of Income and Capital Combined" - cancelled in 1991.

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IT-233R "Lease-Option Agreements; Sale-Leaseback Agreements"

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Articles

Mike Vantil, Greg C. Boehmer, "Caveat Venditor: Let the Seller Beware", Corporate Structures and Groups, Vol VII, No. 3, 2002, p. 372: Discussion of Application of s. 16(1)(a) to Sale Transactions.

Richardson, "Purchase and Sale of a Business: Income Tax Aspects of Warranties, Price Adjustments, and Earn-Outs", 1990 Corporate Management Tax Conference, pp. 10:8-10:9

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Subsection 16(3) - Obligation issued at discount