Proceeds of Disposition

Cases

Valley Equipment Limited v. Canada, 2008 DTC 6200, 2008 FCA 65

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Mollinaro v. The Queen, 2000 DTC 6114 (FCA)

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Bellingham v. The Queen, 96 DTC 6075 (FCA)

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Prince Rupert Hotel (1957) Ltd. v. The Queen, 95 DTC 5227 (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. Demers, 86 DTC 6411, [1986] 2 CTC 321 (FCA)

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See Also

656203 Ontario Inc. v. The Queen, 2003 DTC 405, 2003 TCC 264

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Estate of Myrth May Stuart v. The Queen, 2003 DTC 329, 2003 TCC 171, aff'd supra.

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BP Canada Energy Resources Co. v. The Queen, 2002 DTC 2110 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments 190

Molstad Development Co. Ltd. v. The Queen, 97 DTC 913 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt forgiveness of debt used to finance inventory 85

Wighton v. The Queen, 96 DTC 1310 (TCC)

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Fielder v. Vedlynn Ltd., [1992] BTC 347 (Ch. D.)

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Sénécal v. MNR, 93 DTC 1155 (TCC)

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J.F. Burns Sand & Gravel v. MNR, 68 DTC 226 (TAB)

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Administrative Policy

23 May 2013 External T.I. 2012-0472101E5 F - Emphytéose - disposition de terrain

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20 December 2002 Internal T.I. 2002-0147967 - TAX IMPLICATIONS CONTRACT TERMINATION

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(e) 97
Tax Topics - Income Tax Act - Section 9 - Compensation Payments termination of advisory agreemment with external MFT manager gave rise to capital receipt 267

21 August 1995 T.I. 951975 (C.T.O. "Proceeds of Disposition")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1) 89

24 March 1995 T.I. 950729 (C.T.O. "Sale Price of Shares - Closing")

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93 C.R. - Q. 42

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5 April 1991 T.I. (Tax Window, No. 3, p. 6, ¶1268)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.1) 47

89 C.R. - Q.7

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See Also

Ritchie v. The Queen, 2018 TCC 113

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subpargraph 12(1)(x)(viii) an early signing bonus was part of the proceeds of disposition of the subject property 289

Deragon v. The Queen, 2015 TCC 294

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) reverse earnout amounts included in proceeds 233
Tax Topics - General Concepts - Effective Date proceeds reduced by subsequent settlement pursuant to price adjustment clause 195

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Cases

The Queen v. Shaw, 93 DTC 5121 (C.A.)

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Damka Lumber & Development Ltd. v. The Queen, 90 DTC 6101 (FCTD)

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Sani Sport Inc. v. The Queen, 87 DTC 5253, [1987] 1 CTC 411 (FCTD), aff'd 90 DTC 6230 (FCA)

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E.R. Fisher Ltd. v. The Queen, 86 DTC 6364, [1986] 2 CTC 114 (FCTD)

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See Also

Drummond v. Brown, [1984] BTC 142 (C.A.)

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IRC v. Metrolands (Property Finance) Ltd., [1982] BTC 8032 (HL)

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Choice Realty Corp. v. The Queen, 78 DTC 6415, [1978] CTC 613 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) s. 20(1)(n) reserve not claimed in alternative until subsequent years was statute-barred 137
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate 121

Administrative Policy

7 October 1991 T.I. (Tax Window, No. 10, p. 23, ¶1505)

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18 September 89 T.I. (February 1990 Access Letter, ¶1107)

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Administrative Policy

25 May 2001 Internal T.I. 2001-0085000 - Bituminous sands in-situ projects

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11 June 1996 T.I. 961654 (C.T.O. "Compensation for Expropriated Land")

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Administrative Policy

4 March 2015 External T.I. 2014-0550761E5 F - 44(1) et disposition partielle

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(f) inclusion of insurance proceeds applied to building repair 102
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property part of building treated as former business property 153
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1) partial destruction of building 187

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Cases

Dunne v. The Queen, 96 DTC 6400 (FCTD)

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Administrative Policy

84 C.R. - Q.46

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 20