Start-Up and Close-Down Expenditures

Cases

Caballero v. The Queen, 2009 DTC 1360, 2009 TCC 390

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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" 112

MNR v. M.P. Drilling Ltd., 76 DTC 6028, [1976] CTC 58 (FCA)

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Pigott Investments Ltd. v. The Queen, 73 DTC 5507, [1973] CTC 65 (FCTD)

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Bowater Power Co. Ltd. v. MNR, 71 DTC 5469 (FCTD)

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Williams Brothers Canada Ltd. v. MNR, 62 DTC 1276, [1962] CTC 448 (Ex Ct)

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See Also

Robinson v. The Queen, 2019 TCC 181 (Informal Procedure)

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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 218

Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576 (TCC)

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RTZ Oil and Gas Ltd. v. Elliss, [1987] BTC 359 (Ch. D.)

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Duthie Estate v. MNR, 92 DTC 1043 (TCC)

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Administrative Policy

21 February 2019 Internal T.I. 2019-0796791I7 - Mining Expenditure Review Table

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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 270

27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures

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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" 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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