Subtopics
Cases
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336, [1998] 1 CTC 213
On the winding-up of its wholly-owned subsidiary, the taxpayer received heavy equipment that had been used in the subsidiary's leasing business....
See Also
Thibeault v. The Queen, 2015 TCC 271
In finding that the taxpayer was precluded by the preamble to s. 20(1) from deducting CCA respecting boats which he no longer was leasing,...
Administrative Policy
11 October 2019 APFF Roundtable Q. 2, 2019-0812611C6 F - Résiliation d'un bail - Lease cancellation
A tenant had been annually renewing a lease of a personal-use condo since the time the condo was first leased in July 2013. The condo was sold in...
22 June 2015 Internal T.I. 2014-0553731I7 - Deduction of Terminal Loss - Wind-up
A corporation ("Parentco") received depreciable property of its subsidiary on a s. 88(1) winding-up with no intention of using the property for an...
5 March 2012 Internal T.I. 2010-0384681I7 - Preamble to subsection 20(1) of the Income Tax Act
the applicable-to-source test in the preamble "requires that expenses described in paragraphs 20(1)(a) - (ww) of the Act must be prorated between...
7 October 2011 Roundtable, 2011-0412061C6 F - Financing Expenses
If an issuer intends only to realize capital gains from its investments, would its issue expenses be deductible under the s. 20(1)(e)(i)? CRA...
2003 Ruling 2003-001372
Favourable rulings given with respect to transactions for the transfer of losses of a parent public corporation to its profitable subsidiary...
7 March 2001 Internal T.I. 2001-007215
A taxpayer will be entitled to deduct over time the entire amount of the cost of depreciable property notwithstanding that such property,...
2000 Ruling 2000-0038963 - Affiliated group of persons loss ATIL
Depreciable assets transferred on a rollover basis to a wholly-owned subsidiary which then amalgamated were acquired by it for the purpose of...
5 June 1997 Internal T.I. 9704727 - SPECIAL WARRANT ISSUE COSTS
After referring, with respect to a question as to the deductibility of issue expenses incurred for special warrants, to the requirements in the...