28 March 2012 External T.I. 2011-0430411E5 - Conversion of capital property to inventory -- attach -- Computation of Profit
intended conversion of apartment buildings to condos
Computation of Profit
5 April 2013 External T.I. 2012-0471151E5 F - Binding Agreement -- attach -- Computation of Profit
side letter would not reduce owner’s entitlement to rents from property if not entered into at same time as property acquisition
7 February 2018 External T.I. 2016-0673331E5 - Stock Options - CCPCs -- attach -- Computation of Profit
non-s. 7 stock options received by employee valued at more than their intrinsic value - and treated like securities on and after exercise
9 May 2016 Internal T.I. 2016-0638461I7 - Vehicle provided to subcontractor -- attach -- Computation of Profit
the value of a free automobile to be included in s. 9 income should reflect what the recipient would normally charge for its services
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report -- attach -- Computation of Profit
Anthony v. Canada (National Revenue), 2016 FC 955 -- attach -- Computation of Profit
matching principle not a rule of law
8 October 2004 APFF Roundtable Q. 36, 2004-0087041C6 F - Option d'achat d'actions conférée à un consultant -- attach -- Computation of Profit
value of stock option granted to consultant generally is business income – and gain on exercise may also be business income
Saskferco Products Inc. v. The Queen, 2007 DTC 1183, 2007 TCC 462, aff'd 2008 FCA 297 -- attach -- Computation of Profit
Chronis v. The Queen, 2010 DTC 1188 [at at 3441], 2010 TCC 218 -- attach -- Computation of Profit
11 September 2001 External T.I. 2001-0087365 - SHORT SALES -- attach -- Computation of Profit
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