Cases
Kruger Incorporated v. Canada, 2016 FCA 186
The taxpayer ("Kruger") engaged in extensive trading of FX options, mostly writing European style puts and calls, although it also purchased FX...
Canadian Imperial Bank of Canada v. Canada, 2000 DTC 6207 (FCA)
Before finding that gold and silver bullion of the taxpayer qualified as inventory, Sharlow J.A. indicated (at p. 6210):
"Property is 'described...
Hollinger Inc. v. R., 99 DTC 5500, [1999] 4 CTC 61 (FCA)
The taxpayer, as the result of a series of transactions, acquired companies whose shares had a nominal fair market value but a substantial...
Canada v. Pardee Equipment Limited, 99 DTC 5012, [1999] 1 CTC 101 (FCA)
The taxpayer, which was a farm equipment dealer, was found to have received equipment from the distributor (Deere Canada) on consignment, rather...
Cargill Ltd. v. R., 98 DTC 6126, [1998] 2 C.T.C. 192 (FCA)
The taxpayer, which operated licensed grain elevators, would sell grain that was still owned by the producers who had delivered the grain to the...
Friesen v. Canada, 95 DTC 5551, [1995] 3 S.C.R. 103
Major J. found that a real estate property held by the taxpayer and others in connection with an adventure or concern in the nature of trade...
The Queen v. Bastion Management Ltd., 94 DTC 6272, [1994] 2 CTC 70 (FCTD), aff'd 95 DTC 5238 (FCA)
The taxpayer, which was a trader in commodity futures, purchased 15,000 ounces of gold and 500,000 ounces of silver shortly before its year-end...
Friesen v. The Queen, 93 DTC 5313, [1993] 2 CTC 113 (FCA), rev'd supra.
In his concurring reasons for judgment, Marceau J.A. found that a single property held in connection with an adventure or concern in the nature of...
West Hill Redevelopment Co. Ltd. v. The Queen, 91 DTC 5430, [1991] 2 CTC 83 (FCTD)
The taxpayer (a real estate developer) held mortgages which it received on the sale of condominiums to maturity. Because there is no evidence that...
Stearns Catalytic Ltd. v. The Queen, 90 DTC 6286, [1990] 1 CTC 398 (FCTD)
A stock of spare parts which were held indefinitely until such time, as if any, as they were required as a result of break-downs at two production...
The Queen v. Mattabi Mines Ltd., 89 DTC 5357, [1989] 2 CTC 94 (FCTD), aff'd 92 DTC 6252 (FCA)
After making particular reference to the meaning of "incorporated into" and "processed into," Teitelbaum J. accepted the submission of the Crown...
The Queen v. Dresden Farm Equipment Ltd., 89 DTC 5019 (FCA)
Goods held by the taxpayer were not inventory because they were not owned by the taxpayer.
Saskatchewan Co-Operative Credit Society Ltd. v. The Queen, 85 DTC 5599, [1986] 1 CTC 53 (FCA)
The absence of a finding that the taxpayer was a trader or had otherwise acquired shares intending to turn them to profit by resale precluded a...
Saskatchewan Wheat Pool v. The Queen, 85 DTC 5034, [1985] 1 CTC 31 (FCA)
Grains that were owned by another person nonetheless formed part of the taxpayer's inventory because variations in the grains' quality or quantity...
Qualico Developments Ltd. v. The Queen, 84 DTC 6119, [1984] CTC 122, 84 DTC 6126 (FCA)
At 6124:
"[T]he stock in trade of a business is that which the business offers for sale in the ordinary course of its trade. An item not so...
The Queen v. Jawl Industries Ltd., 74 DTC 6133, [1974] CTC 147 (FCTD)
Lumber which the taxpayer had contracted to purchase but which would not become property of the taxpayer until the time of delivery in a...
Minister of National Revenue v. Freud, 68 DTC 5279, [1968] CTC 438, [1969] S.C.R. 75
Before finding that the taxpayer has sustained a fully deductible loss on advances which he had made to a business venture, Pigeon J. stated (pp....
Minister of National Revenue v. Curlett, 67 DTC 5058, [1967] CTC 62, [1967] S.C.R. 280
The taxpayer, who advanced money at a substantial discount on second mortgage loans, was found to be engaged in a money-lending business....
Ted Davy Finance Co. Ltd. v. MNR, 64 DTC 5124, [1964] CTC 194 (Ex Ct)
Proceeds received by the taxpayer, which carried on the business of purchasing conditional sales contracts (mostly from a related used car dealer)...
Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)
Materials used by a contractor in performing services under contracts were not inventory.
See Also
Kruger Incorporated v. The Queen, 2015 DTC 1127 [at at 788], 2015 TCC 119, rev'd 2016 FCA 186
The taxpayer traded foreign currency options, with its principal option activity being the writing of European-style puts and calls. Rip J found...
Malo v. The Queen, 2012 DTC 1214 [at at 3588], 2012 TCC 75 (Informal Procedure)
After finding that the taxpayer's losses from his stake in a tree-planting operation could not be deducted by virtue of failing to comply with the...
Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.)
Supplies of stationery and special forms on hand at the end of the year were not inventory because they had no market value at all and were of no...
Administrative Policy
18 July 2022 External T.I. 2021-0887121E5 - Feeder Cattle Loan Guarantee Program
In order to assist its members in the production of feeder cattle, a feeder cattle finance cooperative established under the Co-operative...
29 January 2015 Internal T.I. 2014-0544651I7 - Section 85 transfer of Swap Contracts
CRA found that cross-currency swaps with accrued gains, which for redacted reasons were considered to be held on income rather than capital...
21 December 2004 External T.I. 2004-0085481E5 F - Titres détenus par une compagnie d'assurance
After noting that units of a mutual fund trust held by an insurance company are not "mark-to-market property," CRA indicated that, based on
7 November 1996 External T.I. 9628025 - MANDATORY INVENTORY ADJUSTMENT
"Where an amount of the purchase price is allocated for unharvested trees in the field, these trees would be considered purchased inventory ..."
88 CPTJ - Q.17
Where the acquirer of seismic data is acquiring the data solely for resale, the cost is viewed as not being CEE but the cost of an inventory item....
IT-473 "Inventory Valuation"
IT-51R2 "Supplies On Hand at the End of a Fiscal Period"
Included in inventories are expenditures for assets which good financial reporting dictates should be deferred and not written off until the year...
IT-345R "Special reserve - Loans secured by mortgages", para. 2
loans made by a taxpayer in a money-lending business do not qualify as inventory.
IT-466 "Trust Companies"
mortgage loans are not inventory.
Articles
Henry, "Contingent Loan Loss Reserves of Financial Institutions", 1985 Conference Report, pp. 45:13-17
Loans are inventory of money-lending institutions