Cases
MNR v. M.P. Drilling Ltd., 76 DTC 6028, [1976] CTC 58 (FCA)
The taxpayer was incorporated in 1963 for the primary purpose of marketing liquified petroleum gases in the Pacific Rim, and incurred substantial...
Pigott Investments Ltd. v. The Queen, 73 DTC 5507, [1973] CTC 693 (FCTD)
The taxpayer, which was a construction company, caused its subsidiary ("Wentworth") to enter into a contract with the City of Hamilton respecting...
Bowater Power Co. Ltd. v. MNR, 71 DTC 5469, [1971] CTC 818 (FCTD)
The cost of engineering studies commissioned by the taxpayer (an operating hydro-electric company) to determine the feasibility of establishing...
Williams Brothers Canada Ltd. v. MNR, 62 DTC 1276, [1962] CTC 448 (Ex Ct)
A joint venture consisting of two companies ("Mannix" and "Canadian Pipe") successfully bid for a contract to construct a major pipeline. The...
See Also
Caballero v. The Queen, 2009 DTC 1360, 2009 TCC 390
Various professional expenses that the taxpayer incurred with respect to a proposed venture of providing on-site mobile message therapy services...
Robinson v. The Queen, 2019 TCC 181 (Informal Procedure)
The taxpayer (with modest success) sought to follow a pattern of first investigating and developing opportunities and then dropping any resulting...
Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576, [1987] 2 CTC 2311 (TCC)
Expenses incurred by the taxpayer in sending senior offices to Australia to review a potential opportunity to expand its business there were...
RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)
The taxpayer, which had a 25% interest in an oil field under the North Sea, was not permitted to deduct a provision for the estimated costs to be...
Duthie Estate v. MNR, 92 DTC 1043, [1992] 1 CTC 2099 (TCC)
Various fees including architectural fees and project planning fees paid by the taxpayer in connection with the proposed development of land as a...
Administrative Policy
6 June 2019 CPTS Roundtable, 2019-0816111C6
Rio Tinto found that investment dealer fees incurred in connection with an acquisition but before the board determined to make the acquisition...
21 February 2019 Internal T.I. 2019-0796791I7 - Mining Expenditure Review Table
Rio Tinto found that expenditures incurred determining whether to proceed with an acquisition on capital account are currently deductible. ...
27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures
What is the treatment, for taxation purposes, of the expenses incurred by the taxpayer prior to obtaining government authorization to operate a...
23 May 1995 Internal T.I. 9510337 - ENVIRONMENTAL CLEAN-UP COSTS
Environmental clean-up expenditures were on capital account.