Cost Amount

Cases

Praxair Canada Inc. v. The Queen, 93 DTC 5100 (FCTD)

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The Queen v. Dresden Farm Equipment Ltd., 89 DTC 5019 (FCA)

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Administrative Policy

5 October 2015 Internal T.I. 2014-0522241I7, rev'd supra - T1135: Mineral rights situated outside of Canada

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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 163

31 May 1999 External T.I. 5-990674 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 206 - Subsection 206(2) 43

1996 Ruling 960994

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92 CPTJ - Q.8

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30 July 1992 T.I. 921871 (April 1993 Access Letter, p. 153, ¶C248-131)

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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)

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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.

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Paragraph (e)

Administrative Policy

12 April 2016 External T.I. 2015-0595461E5 - Australian Super Fund & T1135

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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 285
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 164
Tax Topics - Income Tax Act - Section 233.2 - Subsection 233.2(1) - Exempt Trust Australian Superannuation Fund not an exempt trust due to taxability 103

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