Cases
Canada v. Rio Tinto Alcan Inc., 2018 FCA 124
Pelletier JA confirmed the distinction between fees relating to acquisition and divestiture transactions of the taxpayer (“Alcan”) that were...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company | 492 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) | takeover bid circular was not a financial report | 175 |
The Queen v. Young, 89 DTC 5234, [1989] 1 CTC 421 (FCA)
The taxpayer, a retiree, "was assembling a portfolio of equity shares...with a view to expanding the capital base by reinvesting the earnings...
Firestone v. The Queen, 87 DTC 5237, [1987] 2 CTC 1 (FCA), rev'g 86 DTC 6405, [1986] 2 CTC 251 (FCTD)
Expenditures incurred by the taxpayer in assembling a conglomerate of four companies were non-deductible: "an expenditure for the acquisition or...
See Also
Watson as trustee for the Murrindindi Bushfire Class Action Settlement Fund v Commissioner of Taxation, [2020] FCAFC 92
The taxpayer was the scheme administrator of an arrangement for the distribution of the $300 million agreed to be paid by the defendants in a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | administration of litigation trust (generating interest income) was not a business | 265 |
Wickham Estate v. The Queen, 2015 DTC 10125 [at 102], 2014 TCC 352 (Informal Procedure)
Investment management fees paid by the taxpayer were fully deductible under s. 20(1)(bb) except for the portion thereof that was denied under s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(u) | pro rata denial based on portfolio portion invested in RRIF | 46 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | payments to (otherwise) retired investment manager deductible | 271 |
Revenue and Customs Commissioner v. Peter Clay Discretionary Trust, [2009] 2 WLR 1353 (CA)
Fees of investment advisors incurred by a discretionary trust were on capital account because they were incurred after the trustees had resolved...
Wilson v. MNR, 80 DTC 1379, [1980] CTC 2431 (T.R.B.)
The taxpayer, who derived 1/3 of his income or approximately $20,000 per annum, from a portfolio of stocks and bonds was able to deduct the $1,020...
Administrative Policy
6 June 2019 CPTS Roundtable, 2019-0816111C6
What is the characterization of pre-Final Investment Decision (“FID”) expenses, i.e., are expenses incurred prior to the approval of a project...
23 March 2007 External T.I. 2006-0207071E5 - Investment Counsel Fees
A performance fee break (based on percentage increases in the fair market value of the portfolio that was being managed) might be deductible,...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | 45 |
5 March 2003 External T.I. 2002-0151405 - Transaction Costs - Aborted Acquisition
Various fees paid by a taxable Canadian corporation with respect to its proposed acquisition of another taxable Canadian corporation would be...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | 149 |
26 April 2002 Internal T.I. 2002-0129707 F - FRAIS D'OUVERTURE DE COMPTE
An administrative fee paid by a shareholder on becoming an account holder would be a capital expense that was an addition to the ACB of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | admin fee for shares that generate only capital gains is an ACB addition | 52 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | admin fee for shares that generate only capital gains cannot be deducted under s. 20(1)(bb) | 55 |
17 July 2001 External T.I. 2001-0068355 F - DEDUCTION D'UN BONI A UN EMPLOYE
Regarding whether a performance bonus paid to an employee based on the appreciation in value of a capital property that the employer disposed of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | bonus paid to manage investments would not be a disposition expense | 121 |
10 June 1998 Internal T.I. 9808707 - TRAVEL PROMO AND SALARY EX FOR INVEST CORP
Travel expenses incurred by employees of a corporation whose sole activity was the investment of its capital in shares and other instruments would...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 17 |