Property

Table of Contents

Cases

Spezzano v. Canada, 2007 DTC 5580, 2007 FCA 294

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Tax Topics - Income Tax Act - Section 9 - Compensation Payments compensation received by landlord for lease cancellation was on income account 102

Canada v. Haché, 2011 DTC 5089 [at 5848], 2011 FCA 104

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Rezek v. Canada, 2005 DTC 5373, 2005 FCA 227

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Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] S.C.R. 680

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Slobodrian v. Canada (Minister of National Revenue), 2003 DTC 5632, 2003 FCA 350

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Manrell v. Canada, 2003 DTC 5225, 2003 FCA 128, rev'd 2003 DTC 5225, 2003 FCA 128

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Royal Bank of Canada v. Tuxedo Transport Ltd., 2000 DTC 6501 (BCCA)

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Tax Topics - Income Tax Act - Section 227 - Subsection 227(4.1) 73

Romkey v. Canada, 2000 DTC 6047 (FCA)

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La Capitale, Compagnie d'Assurance Générale v. Canada, 98 DTC 6428 (FCA)

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Vaillancourt v. The Queen, 91 DTC 5352 (FCTD)

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Shaw v. The Queen, 89 DTC 5194 (FCTD), aff'd 93 DTC 5213 (FCA)

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Pe Ben Industries Co. Ltd. v. The Queen, 88 DTC 6347, [1988] 2 CTC 120 (FCTD)

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The Queen v. Golden et al., 86 DTC 6138, [1986] 1 CTC 274, [1986] 1 S.C.R. 209

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The Queen v. Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA)

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The Queen v. Burgess, 81 DTC 5192, [1981] CTC 258 (FCTD)

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Murphy v. The Queen, 80 DTC 6314, [1980] CTC 386 (FCTD)

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The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA)

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Rapistan Canada Ltd. v. MNR, 74 DTC 6426, [1974] CTC 495, briefly aff'd 76 DTC 6177, [1976] CTC 296 (SCC)

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Quality Chekd Dairy Products Association v. MNR, 67 DTC 5303 (Ex Ct)

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Huston v. MNR, 61 DTC 1233, [1961] CTC 414 (Ex.Ct.)

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Industrial Development Bank v. Valley Dairy Ltd., 53 DTC 1027, [1953] CTC 132 (Ont. S.C.)

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Words and Phrases
assets

See Also

Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 - Paragraph (a) goodwill must have a connection to attracting custom 453
Tax Topics - General Concepts - Fair Market Value - Other discounted cash flow valuation undervalued resource lands and residual valuation overstated goodwill 312

Aitchison Professional Corporation v. The Queen, 2018 TCC 131

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Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) s. 160(1) did not apply to a tax debtor providing services free of charge to the NAL transferee of his professional practice 332

Iberville Developments Limited v. The Queen, 2018 TCC 102

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) the starting ACB of a partnership interest was determined exclusively under s. 97(2)(b) 620
Tax Topics - Income Tax Act - Section 97 - Subsection 97(1) s. 97(1) establishes FMV cost for partner's interest 130

Carson v. The Queen, 2014 DTC 1006 [at 2520], 2013 TCC 353 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts donated space must constitute an enforceable right in order to be property 107

Winsor v. The Queen, 2008 DTC 2116, 2007 TCC 692

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Roth v. The Queen, 2005 DTC 1570, 2005 TCC 484, aff'd 2007 DTC 5222, 2007 FCA 38

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) know-how not property 77
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense purported transfer of knowhow to corportion did not entail acquisition of property 96

QEW 427 Dodge Chrysler (1991) Inc. v. Minister of Revenue (2000), 49 OR (3d) 776 (S CT J), aff'd (2002), 50 OR (3d) 460 (S Ct J, Div Ct), 2002 DTC 7228

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Marzetti v. Marzetti (1994), 26 C.B.R. (3d) 161, [1994] 2 S.C.R. 765

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Canadian Imperial Bank of Commerce v. Hallahan (1990), 48 BLR 113 (Ont CA)

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Drummond v. Smith (1988), 18 R.F.L. (3d) 120 (Alta. Q.B.)

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Re National Trust Co. and Bouckhurst (1987), 61 OR (2d) 640 (C.A.)

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Kirby v. Thorn EMI plc, [1987] DTC 462 (CA)

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O'Brien v. Benson's Hosiery (Holdings) Ltd. (1979), 53 TC 241 (HL)

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Manitoba Fisheries Ltd. v. The Queen, [1979] 1 S.C.R. 101.

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The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)

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Minister of Revenue (Ontario) v. McCreath, [1976] CTC 178, [1977] 1 S.C.R. 2

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Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] S.C.R. 680

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Technical Tape Corp. v. MNR, 64 DTC 428 (TAB)

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) variable payments wer for use of knowhow 123

Minister of National Revenue v. Fitzgerald, [1949] CTC 101, [1949] S.C.R. 453 (SCC)

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Federal Commissioner of Taxation v. United Aircraft Corp. (1943), 7 A.T.D. 318 (HC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) provision of knowhow in the US to Australian company not carrying on business in Australia 195

Musker v. English Electric Co. Ltd., 41 TC 556 (HL)

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Nokes v. Doncaster Amalgamated Collieries Ltd., [1940] A.C. 1014 (HL)

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Words and Phrases
property property acquired

Curtis Brown, Ltd. v. Jarvis (1929), 14 TC 744 (K.B.D.)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) 119

Administrative Policy

20 January 2014 External T.I. 2013-0503871E5 F - Vente d'une érablière

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6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 10, 2017-0705201C6 F - Capital loss - repayment of loan

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.3) the foreign currency deemed to be disposed of under s. 39(2) by an FX borrower on repaying a USD loan is not identical property to the USDs received by it under a replacement loan 348

6 October 2017 APFF Roundtable Q. 16, 2017-0709161C6 F - Résidence principale sur une terre agricole

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Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Interest in a Family Farm or Fishing Partnership - Paragraph (a) - Subparagraph (a)(i) a legally non-severable farm that is used both in farming and as a residence is one property for purposes of the s. 110.6 principal-use tests 283

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F - Changement d'usage - duplex

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) substantially renovating the personal-use portion of a rental property (without changing floor areas) generally would not engage the change-of-use rules 233
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) apportionment of operating expenses of duplex used both personally and for rental income 159

29 November 2016 CTF Roundtable Q. 8, 2016-0671501C6 - 55(2) clause 55(2.1)(b)(ii)(B)

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) cash is property for 55(2.1)(b)(ii)(B) purposes 127

3 March 2015 External T.I. 2014-0519981E5 F - Donation avec charge / Gift with a charge

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) gift of encumbered property 146

6 October 2014 External T.I. 2014-0543751E5 F - Rollover of a part of an interest in a partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) fractional partnership interest qualifies as eligible property 69

12 June 2012 STEP CRA Roundtable, 2012-0442921C6 - STEP CRA Roundtable - June 2012 Q.9

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19 January 2011 External T.I. 2010-0390831E5 - Compute LRIP - corporation becomes non-CCPC

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1998 A.P.F.F. Round Table, Q. 14, No. 9824750

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27 April 1998 TI 980014

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23 September 1996 External T.I. 5-962304 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) pre-patent right included 25

8 November 1995 Memorandum 952507

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24 April 1995 T.I. 942950 (C.T.O. "Milk Quota")

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29 March 1995 Memorandum 950250 (C.T.O. "Right to Royalty Eligible Property")

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) 73

3 October 1994 External T.I. 5-942411 -

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 32

24 March 1992 T.I. (920203 (March 1993 Access Letter, p. 76, ¶C109-126; Tax Window, No. 18, p. 24, ¶1827)

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81 C.R. - Q.86

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Articles

Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377

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Wilson, "Tax Treatment of Development, Acquisition, and Transfer of Technology", 1983 Conference Report, pp. 857-867

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