Adjusted Cost Base

Cases

Bernick v. Canada, 2004 DTC 6409, 2004 FCA 191

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Tax Topics - General Concepts - Evidence foreign law presumed the same 62
Tax Topics - Income Tax Act - Section 9 - Accounting Principles accounting method must produce an accurate result 179
Tax Topics - Income Tax Act - Section 9 - Computation of Profit 179

Trzop v. Canada, 2002 DTC 6728, 2001 FCA 380

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The Queen v. Rumack, 92 DTC 6142 (FCA)

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Bodrug Estate v. The Queen, 90 DTC 6521 (FCTD), aff'd 91 DTC 5621 (FCA)

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Watkins v. The Queen, 90 DTC 6432 (FCTD)

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Gaynor v. The Queen, 88 DTC 6394 (FCTD), aff'd 91 DTC 5288 (FCA)

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Wise v. The Queen, 86 DTC 6023, [1986] 1 CTC 169 (FCA)

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Tax Topics - General Concepts - Onus 39

The Queen v. Stirling, 85 DTC 5199, [1985] 1 CTC 275 (FCA)

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The Queen v. Pollock, 84 DTC 6370, [1984] CTC 353 (FCA)

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See Also

Lockwood Financial Ltd. v. The Queen, 2020 TCC 128

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) shares received on a deferred basis from a successor of a client were fee income in the year of entitlement to receive 497

D’Anjou v. The Queen, 2019 CCI 208

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) the taxpayer should have been informed by a similar loss in the Court of Quebec 141

Devon Canada Corporation v. The Queen, 2018 TCC 170

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it 309
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) quaere whether “sale” includes a sale to a 3rd party 177
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) stock option surrender payments of target deductible under s. 111(5.2) 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition of surrendered stock options occurred under doctrine of merger 318

Plains Midstream Canada ULC v. The Queen, 2017 TCC 207, aff'd 2019 FCA 57

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Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) s. 16(1) operates symmetrically (no creditor interest – no debtor interest deduction) 442

The Armour Group Limited v. The Queen, 2017 TCC 65, aff'd 2018 FCA 134

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation structuring to deduct most of the cost of land (or a ground leasehold interest therein) was unsuccessful 565

Coast Capital Savings Credit Union v. Canada, 2016 FCA 181

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Tax Topics - General Concepts - Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant 282
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) rejection of apparent attempt to argue that an inflated purchase price should be bifurcated between a FMV cost and a benefit conferral 294

Turner v. The Queen, 2016 TCC 77 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss averaging-down investment in one public company not indicative of business 180

Kokai-Kuun Estate v. The Queen, 2015 TCC 217

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) failure to elect 151

Brosamler Estate v. The Queen, 2012 DTC 1193 [at 3493], 2012 TCC 204 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) probate fees to establisih title 138

Eskandari v. The Queen, 2007 DTC 1406, 2007 TCC 419 (Informal Procedure)

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Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476

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Graphic Packaging Canada Corp. v. The Queen, 2001 DTC 861 (TCC), aff'd 2003 DTC 5007 (FCA)

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Tax Topics - Income Tax Act - Section 54 - Superficial Loss 91

Bow River Pipelines Ltd. v. Canada, 2000 DTC 6090 (FCA)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(1) partnership deemed to continue until distribution 186

R. v. Inland Revenue Commissioners, Ex Parte Matrix Securities Ltd., [1994] BTC 85 (HL)

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Glass v. MNR, 92 DTC 1759 (TCC)

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Ensign Tankers (Leasing) Ltd. v. Stokes, [1992] BTC 110 (HL)

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Riendeau v. MNR, 85 DTC 665 (TCC)

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Stanton v. Drayton Commercial Investment Co. Ltd., [1982] BTC 269, [1982] 2 All E.R. 943 (HL)

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Tax Topics - General Concepts - Fair Market Value - Shares 60

MNR v. Enjay Chemical Co. Ltd., 71 DTC 5293, [1971] CTC 535 (FCTD)

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 99
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt debt forgiveness related to inventory of operations 178

Bentley v. Pike (1981), 53 TC 590 (Ch. D.)

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Craddock v. Zevo Finance Co. Ltd. (1946), 27 TC 267 (HL)

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Administrative Policy

2017 Ruling 2017-0699201R3 - Cross-border Butterfly

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution cross-border butterfly with 4-party exchange and preceding distribution of DC to foreign parent to qualify as permitted exchange/rental property valued at nil/post-butterfly equaling cash payment 1140
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Permitted Exchange - Paragraph (b) cross-border butterfly including preliminary transfer of DC to foreing parent to come within “permitted exchange” 444
Tax Topics - Income Tax Act - Section 143.3 - Subsection 143.3(3) s. 143.3(3) inapplicable on a 4-party exchange 234
Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(1.1) - Paragraph 212.1(1.1)(b) application on 4-party exchange 291

14 March 2016 Internal T.I. 2015-0609671I7 - Earnout, Amalgamation, Cost of Shares and ECE

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) post-amalgamation earnout payment could be applied to increase an s. 88(1)(d) bump of capital property (but not ECP) of the amalgamated target 317
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payments made by Amalco in satisfaction of earnout obligation for acquisition of one precedessor by the other were not ECE 224
Tax Topics - General Concepts - Purpose/Intention attribution of predecessor's intention to Amalco 140
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) position on interest deductibility following target amalgamation is based on policy and ITA scheme rather than technical 350

22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) FMV cost of property acquired on QROC distribution 121
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) FMV cost of property acquired on contribution of capital 121
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure QROC distribution by a foreign affiliate to its Canadian shareholder of ECP results in ECE to the shareholder of the property’s FMV 220
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element A.1 no gain to FA transferor of ECP 99

11 October 2013 APFF Roundtable Q. 18, 2013-0495851C6 F - Safe income adjustments

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) CRA post-closing reassessment of Target's pre-closing income changes its SIOH 392

10 June 2013 STEP Round Table Q. 10, 2013 0480411C6 (Brosamler decision)

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20 March 2013 External T.I. 2012-0442571E5 F - Coût d'acquisition d'un terrain

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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 cost of water and sewer lines connecting mobile home units, included in Class 8 86

15 November 2012 External T.I. 2012-0461291E5 F - Frais judiciaires pour clarifier une servitude

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) costs of preventing an expanded easement on land were not a disposition expense 265

25 September 2012 Internal T.I. 2011-0409281I7 F - Papier commercial - Obligations XXXXXXXXXX

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss compensating clients for half their loss was currently deducible, whereas purchasing securities at original cost was its cost 158

17 October 2012 Ruling 2010-0376681R3 - Internal reorganization - 55(3)(a)

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3 May 2010 Internal T.I. 2010-0359631I7 F - Dépenses liées à une résidence non habitée

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Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(h) ACB addition for property taxes inapplicable where a building on the property 185

20 November 2009 External T.I. 2009-0332351E5 F - Crédit d'impôt pour la rénovation domiciliaire

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Tax Topics - Income Tax Act - Section 118.04 - Subsection 118.04(1) - Qualifying Expenditure expenditure can come out of money that had already been set aside 63

24 February 2004 External T.I. 2003-004493 -

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2 December 2003 External T.I. 2003-0048585 - Cost of Property Acquired for Shares

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5 March 2003 External T.I. 2002-015145 -

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21 November 1997 External T.I. 9727985 - COST BASIS - FOREIGN TRIANGULAR AMALGAMATION

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3 October 1994 External T.I. 9424115 - EPSP FORFEITURES

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93 C.P.T.J. - Q.29

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15 October 1991 T.I. (Tax Window, No. 11, p. 8, ¶1525)

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(2.1) 33

22 August 1991 T.I. (Tax Window, No. 8, p. 11, ¶1407)

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6 June 1991 Memorandum (Tax Window, No. 4, p. 22, ¶1283)

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13 May 1991 T.I. (Tax Window, No. 3, p. 25, ¶1230)

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5 March 1990 T.I. (August 1990 Access Letter, ¶1383)

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29 Aug. 89 Inter-Office Memo (Jan. 90 Access Letter, ¶1089)

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89 C.P.T.J. - Q11

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87 C.R. - Q.42

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84 C.R. - Q.63

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IT-153R3 "Land Developers - Subdivision and Development Costs and Carrying Charges on Land"

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