Start-Up and Close-Down Expenditures

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...

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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...

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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...

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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...

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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...

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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

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...

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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, [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...

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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...

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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...

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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...

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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 - 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

Rio Tinto found that expenditures incurred determining whether to proceed with an acquisition on capital account are currently deductible. ...

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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

What is the treatment, for taxation purposes, of the expenses incurred by the taxpayer prior to obtaining government authorization to operate a...

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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

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