Regulation 406


British Yukon Railway Co. v. The Queen, 77 DTC 5176, [1977] CTC 256 (FCTD)

Regulation 406 deals only with railway corporations operating between Canadian provinces and accordingly did not apply to the allocation of income from a railroad that ran through Alaska, the Yukon and B.C. The method used by the taxpayer, which was to apply paragraph 1.863-4 of the Regulations to the Internal Revenue Code, was found to be in accord with ordinary business and commercial principles.

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