Eligible Capital Property

Administrative Policy

27 April 1998 External T.I. 9800145 - non-competion agreements, client lists

A lump-sum payment received by the individual shareholder of a corporation upon a sale by that corporation of one of its business divisions and in consideration for a non-compete covenant given by the individual to the purchaser would be regarded as a capital gain arising on a disposition of "property" (the right of the individual to compete).

81 C.R. - Q.6

Notwithstanding Rapistan, know-how that is of a capital nature is eligible capital property.