Cases
Caballero v. The Queen, 2009 DTC 1360, 2009 TCC 390
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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" | 120 |
MNR v. M.P. Drilling Ltd., 76 DTC 6028, [1976] CTC 58 (FCA)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 | 242 |
Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576 (TCC)
RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| 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 - Oversight or Investment Management | project expenses incurred after determining economic feasibility and before project approval are generally deductible | 248 |
| 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 |
21 February 2019 Internal T.I. 2019-0796791I7 - Mining Expenditure Review Table
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 | 580 |
27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) - Paragraph 13(7.5)(b) | access road deemed to have been "acquired" | 201 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 | access road to quarry was Class 17 property notwithstanding that not owned | 164 |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(g) | ordinary meaning of "mineral" | 43 |
23 May 1995 Internal T.I. 9510337 - ENVIRONMENTAL CLEAN-UP COSTS
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | 100 |