Cases
Steeves v. The Queen, 77 DTC 5230 (FCA)
At the same time as the taxpayer and his brother purchased the remaining 50% of the common shares of a road-paving company in financial difficulty...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Debt/ receivables | 107 |
Terminal Dock and Warehouse Co. Ltd. v. MNR, 68 DTC 5060, [1968] CTC 78 (Ex Ct), aff'd 68 DTC 5316 (SCC)
One of the activities of the taxpayer, whose main business was that of a dock and wharfage company, was to finance the purchase of shares in its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | advances to employees on capital account | 120 |
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)...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | conditional sales contracts not invenory | 75 |
See Also
No. 570 v. MNR, 58 DTC 617 (TAB)
The taxpayer was one of 13 partners in a firm of chartered accountants that sold the practice to another firm, including a sale of the...
Crompton v. Reynolds and Gibson, [1952] 1 All E.R. 888, [1952] UKHL TC (HL)
Four successive partnerships (referred to as firms Nos. 1, 2, 3 and 4) carried on business as cotton brokers. Firms Nos. 1 and 2 were deemed to be...
Administrative Policy
1993 A.P.F.F. Round Table, Q.14 (Windows File No. 3M09520)
"The disposition of trade receivables does not normally result in a capital gain or loss ... . However, a taxpayer's trade receivables are...
3 December 1993 External T.I. 9200995 F - Transfer of Farm Inventory to a Corporation
Since the entitlement of a farmer under a gross revenue insurance program constitutes an account receivable to him that relates to the farming...
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|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Other | 66 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 59 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 51 |
30 July 1992 T.I. 921871 [elaborating on 913040 below]
Accounts receivable usually will be regarded as capital property except where the taxpayer is a trader in accounts receivable.
3 June 1992 T.I. 913040
A trade debt held by a creditor is considered to be capital property unless the creditor corporation is in the business of lending money....
1 August 1991 Memorandum 911898
Neither the assignment of accounts receivable to a creditor finance company nor the holding of receivables acquired in the ordinary course of...
4 April 1991 Internal T.I. 7-902723
Whether the amount realized by the vendor corporation in a receivables securitization is deductible by it turns on whether the arrangement is a...
IT-188R Archived "Sale of Accounts Receivable" 22 May 1984
Sale or purchase of trade receivables as part of business on capital account
7. Where a vendor, who...is not a trader in accounts receivable,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) | 116 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 17 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) | 28 |
IT-442R "Bad Debts and Reserves for Doubtful Debts"
Deductibility of bad debt losses on ordinary principles
1. ...[W]here...a debt was of a kind that would have qualified for consideration as a bad...
Commentary
The principle that the purchase (or sale) of all or substantially all the assets of a business occurs on capital account except to the extent that...