Cases
Praxair Canada Inc. v. The Queen, 93 DTC 5100, [1993] 1 CTC 130 (FCTD)
The taxpayer received Class C preference shares of a company in satisfaction of subordinated debentures and unpaid interest owing to it by the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | pref shares received in exchange for debentures had an FMV less than their par value, so that no receipt of unpaid debenture interest | 168 |
The Queen v. Dresden Farm Equipment Ltd., 89 DTC 5019 (FCA)
The taxpayer had no "cost amount" for inventory held by it on consignment because it had incurred no cost for the purchase of the goods....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 178 - Subsection 178(2) | 12 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 18 |
Administrative Policy
5 October 2015 Internal T.I. 2014-0522241I7 - T1135: Mineral rights situated outside of Canada
After finding that a foreign resource property is tangible property for purposes of s. 233, CRA stated:
…[T]he CRA has a longstanding position...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property | foreign mineral right is tangible property | 171 |
31 May 1999 External T.I. 9906745 - FOREIGN PROPERTY - COST AMOUNT
Because the delisting or suspension of trading of a share does not cause the taxpayer to cease to own its share, or cause a disposition of its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 206 - Subsection 206(2) | 45 |
30 November 1995 Ruling 9609943 - FORWARD CONTRACT, MARKETABLE SECURITY
The cost amount for purposes of s. 206(2) of investments in exchange-traded futures contracts and forward currency contracts will be equal to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 206 - Paragraph 206(1)(h) | 25 | |
| Tax Topics - Income Tax Act - Section 206 - Subsection 206(2) | 55 |
92 CPTJ - Q.8
The cost amount of a Canadian resource property is nil irrespective of the existence of undeducted resource pools.
30 July 1992 T.I. 921871 (April 1993 Access Letter, p. 153, ¶C248-131)
Accounts receivable normally would be considered to be capital property, with the result that their cost amount normally would be determined under...
D'Aurelio, "International Issues: A Revenue Canada Perspective", 1990 Conference Report, C. 44, under "Cost Amount of Debt Denominated in Foreign Currency and the Meaning of the Words 'Amount Outstanding at That Time'"
11 December 1989 T.I. (May 1990 Access Letter, ¶1222)
The "amount" of a receivable or other debt is interpreted to mean the face amount of the debt or right to receive an amount and not necessarily...
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", draft version of paper for CTF 2043 Conference Report.
Whether money has cost amount (pp. 10-11)
Section 143.3 applies to limit the cost of "property" acquired by the taxpayer, and does not include an...
Paragraph (b)
Administrative Policy
14 February 2002 External T.I. 2002-0118915 F - BIENS ETRANGERS INTERETS COURUS
CCRA indicated that the cost amount of a guaranteed investment certificate issued by a financial institution that bore interest that is compounded...
13 September 2001 External T.I. 2001-0097675 F - COUT INDIQUE REVENUS A RECEVOIR
CCRA confirmed that the cost amount of shares held as capital property (i.e., ACB) was not increased by the amount of a dividend receivable and...
Paragraph (e)
Administrative Policy
12 April 2016 External T.I. 2015-0595461E5 - Australian Super Fund & T1135
An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property - Paragraph (n) | Australian pension fund subject to 10%-15% tax rate not an exempt fund | 309 |
| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | no penalty for reasonably estimating an unknown amount, e.g., the “cost amount” of a pension interest | 172 |
| Tax Topics - Income Tax Act - Section 233.2 - Subsection 233.2(1) - Exempt Trust | Australian Superannuation Fund not an exempt trust due to taxability | 107 |
Paragraph (f)
Administrative Policy
7 October 2011 Roundtable, 2011-0399441C6 F - T1135 - coût indiqué d'une assurance-vie
The definition of reporting entity in s. 233.3 references its “cost amount” of specified foreign property. Is the cost amount of an interest...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Reporting Entity | cost amount of foreign policy is its adjusted cost basis | 88 |