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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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | 119 |
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...
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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" | 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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| 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...
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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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 124 |
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...
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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 | 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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| 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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| 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
Environmental clean-up expenditures were on capital account.
| 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 |