Cases
Caballero v. The Queen, 2009 DTC 1360, 2009 TCC 390
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | fledgling business should entail "serious and reasonable continuous efforts to begin normal operations" | 112 |
MNR v. M.P. Drilling Ltd., 76 DTC 6028, [1976] CTC 58 (FCA)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 115 |
Pigott Investments Ltd. v. The Queen, 73 DTC 5507, [1973] CTC 65 (FCTD)
Bowater Power Co. Ltd. v. MNR, 71 DTC 5469 (FCTD)
See Also
Robinson v. The Queen, 2019 TCC 181 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 3 | activities of developing assets with a view to their drop-down to corporation likely was a property income source rather than business | 218 |
Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576 (TCC)
RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 118 |
Administrative Policy
6 June 2019 CPTS Roundtable, 2019-0816111C6
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| 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 | 124 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | Folio S4-F15-C1 applies for purposes of the new accelerated CCA rules | 193 |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) | extension of M&P guidance to oil and gas sector | 57 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | project expenses incurred after determining economic feasibility and before project approval are generally deductible | 236 |
| 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 | 125 |
21 February 2019 Internal T.I. 2019-0796791I7 - Mining Expenditure Review Table
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| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | categorization of pre-mining expenditures by ITA treatment | 270 |
27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures
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| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) - Paragraph 13(7.5)(b) | access road deemed to have been "acquired" | 195 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 | access road to quarry was Class 17 property notwithstanding that not owned | 158 |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(g) | ordinary meaning of "mineral" | 41 |
23 May 1995 Internal T.I. 7-951033 -
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | 98 |