Oversight or Investment Management

Cases

Canada v. Rio Tinto Alcan Inc., 2018 FCA 124

Pelletier JA confirmed the distinction between fees relating to acquisition and divestiture transactions of the taxpayer (“Alcan”) that were...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company 492
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular was not a financial report 175

The Queen v. Young, 89 DTC 5234, [1989] 1 CTC 421 (FCA)

The taxpayer, a retiree, "was assembling a portfolio of equity shares...with a view to expanding the capital base by reinvesting the earnings...

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Firestone v. The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)

Expenditures incurred by the taxpayer in assembling a conglomerate of four companies were non-deductible: "an expenditure for the acquisition or...

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See Also

Watson as trustee for the Murrindindi Bushfire Class Action Settlement Fund v Commissioner of Taxation, [2020] FCAFC 92

The taxpayer was the scheme administrator of an arrangement for the distribution of the $300 million agreed to be paid by the defendants in a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business administration of litigation trust (generating interest income) was not a business 265

Wickham Estate v. The Queen, 2015 DTC 10125 [at 102], 2014 TCC 352 (Informal Procedure)

Investment management fees paid by the taxpayer were fully deductible under s. 20(1)(bb) except for the portion thereof that was denied under s....

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(u) pro rata denial based on portfolio portion invested in RRIF 46
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) payments to (otherwise) retired investment manager deductible 271

Revenue and Customs Commissioner v. Peter Clay Discretionary Trust, [2009] 2 WLR 1353 (CA)

Fees of investment advisors incurred by a discretionary trust were on capital account because they were incurred after the trustees had resolved...

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Wilson v. MNR, 80 DTC 1379, [1980] CTC 2431 (T.R.B.)

The taxpayer, who derived 1/3 of his income or approximately $20,000 per annum, from a portfolio of stocks and bonds was able to deduct the $1,020...

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Administrative Policy

6 June 2019 CPTS Roundtable, 2019-0816111C6

What is the characterization of pre-Final Investment Decision (“FID”) expenses, i.e., are expenses incurred prior to the approval of a project...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) taxpayers can choose between reasonable alternative formats (e.g. hard or soft) for providing their tax working papers/records 140
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 Folio S4-F15-C1 applies for purposes of the new accelerated CCA rules 229
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) extension of M&P guidance to oil and gas sector 61
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures no acceptance that expenses incurred before decision to proceed are thereby on current account 186
Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Accelerated Canadian Development Expense - Paragraph (a) - Subparagraph (a)(ii) accelerated CDE deduction can be available for drilling on land acquired from an affiliate 131

23 March 2007 External T.I. 2006-0207071E5 - Investment Counsel Fees

A performance fee break (based on percentage increases in the fair market value of the portfolio that was being managed) might be deductible,...

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

Various fees paid by a taxable Canadian corporation with respect to its proposed acquisition of another taxable Canadian corporation would be...

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26 April 2002 Internal T.I. 2002-0129707 F - FRAIS D'OUVERTURE DE COMPTE

An administrative fee paid by a shareholder on becoming an account holder would be a capital expense that was an addition to the ACB of the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base admin fee for shares that generate only capital gains is an ACB addition 52
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) admin fee for shares that generate only capital gains cannot be deducted under s. 20(1)(bb) 55

10 June 1998 Internal T.I. 9808707 - TRAVEL PROMO AND SALARY EX FOR INVEST CORP

Travel expenses incurred by employees of a corporation whose sole activity was the investment of its capital in shares and other instruments would...

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