Section 68 - Allocation of amounts in consideration for property, services or restrictive covenants

Cases

Transalta Corporation v. Canada, 2012 DTC 5040 [at 6757], 2012 FCA 20

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H. Baur Investments Ltd. v. The Queen, 90 DTC 6371 (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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Words and Phrases
disposition

The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA)

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Salt v. The Queen, 84 DTC 6395, [1984] CTC 414 (FCTD)

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Millers Credit Jewellers Ltd. v. The Queen, 84 DTC 6205, [1984] CTC 218 (FCTD)

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Golden v. The Queen, 83 DTC 5138, [1983] CTC 112 (FCA), aff'd supra.

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Elworthy v. The Queen, 82 DTC 6067, [1982] CTC 62 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Land 62

A.G. Canada v. Matador Inc., 80 DTC 6022, [1980] CTC 51 (FCA)

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Roywood Investments Ltd. v. The Queen, 79 DTC 5451, [1980] CTC 19 (FCTD), aff'd 81 DTC 5148, [1981] CTC 206 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(c) 68
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) land with building was acquired only for purpose of generating capital gain 48

The Queen, v. Leclerc, 79 DTC 5440, [1979] CTC 527 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 69

R. v. Malloney’s Studio Ltd., 79 DTC 5124, [1979] CTC 206, [1979] 2 S.C.R. 326

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The Queen v. Jessiman Brothers Cartage Ltd., 78 DTC 6205, [1978] CTC 274 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 178 - Subsection 178(2) 16

The Queen v. Moulds, 78 DTC 6068, [1978] CTC 146 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Estoppel 103

Dominion Stores Ltd. v. MNR, 66 DTC 5111, [1966] CTC 97 (Ex Ct)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) portion of sales allocated to trading stamps 128

Seaboard Advertising Co. Ltd. v. MNR, 65 DTC 5188, [1965] CTC 310 (Ex. Ct.)

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See Also

Wagner v. The Queen, 2012 DTC 1234 [at 3645], 2012 TCC 8

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) common interest in sharing tax saving 108

FLSmidth Ltd. v. The Queen, 2012 DTC 1052 [at 2745], 2012 TCC 3, aff'd 2013 DTC 5118 [at 6147], 2013 FCA 160

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Robert Glegg Investment Inc. v. The Queen, 2008 DTC 2466, 2008 TCC 20, aff'd , 2009 DTC, 2008 FCA 332

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Staltari v. The Queen, 95 DTC 506 (TCC)

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Spies v. The Queen, 94 DTC 1964 (TCC)

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Inshore Investments Ltd. v. The Queen, 92 DTC 6162 (FCTD)

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Leonard v. MNR, 91 DTC 545 (TCC)

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Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

18 July 2011 External T.I. 2010-0370561E5 F - Location avec option d'achat

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) where lease is coupled with bargain purchase option, a portion of the rents must be allocated to option proceeds 154
Tax Topics - General Concepts - Substance lease is a lease in the absence of sham 86

92 C.R. - Q.9

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September 1991 Memorandum (Tax Window, No. 10, p. 16, ¶1479)

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89 C.M.TC - Q.3

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88 C.R. - F.Q.12

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80 C.R. - Q.16

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80 C.R. - Q.41

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IT-220R2 "Capital Cost Allowance - Proceeds of Disposition of Depreciable Property"

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IT-96R6 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures", para. 9

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IT-304R "Capital Cost Allowance - Condominiums"

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Paragraph 68(c)

Articles

Michael Coburn, "Practical Strategies for Dealing with the Restrictive Covenant Provisions", 2014 Conference Report (Canadian Tax Foundation), 8:1-29

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Jack Bernstein, "Canadian Intangibles, Noncompete Payments, and Allocations of Purchase Price", Practitioner's Corner, Tax Notes International, 26 March 2012, p. 1011

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