Subsection 22(1) - Sale of accounts receivable
See Also
Office Overload Co. Ltd. v. MNR, 65 DTC 690 (TAB)
The election under s. 85D(1) of the pre-1972 Act was not available for accounts receivable included in a business purchased by the taxpayer from a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Person | "person" not to be intepreted as extending to someone not subject to Cdn tax | 118 |
Administrative Policy
S4-F7-C1 - Amalgamations of Canadian Corporations
Amalco can make s. 22 election (if no business interruption)
1.62.1 Where a new corporation that was formed on an amalgamation that was governed...
24 October 2017 Internal T.I. 2017-0719531I7 - Section 22 election and carrying on a business
Following the amalgamation of “Predecessor 1” (which carried on the “Businesses”) with its parent (“Predecessor 2”), Amalco...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(g) | failure of s. 87()2)(g) to deem continuity for s. 22 purposes not fatal | 117 |
12 February 2015 External T.I. 2014-0560491E5 F - Article 22
Would a Canadian corporation which has carried on a business through a non-resident branch and which then sells all or substantially all of the...
27 November 2011 CTF Annual Roundtable Q. 15, 2011-0426271C6 - Subsection 96(3) election
If the conditions in s. 96(3)(a) are met, then the s. 22 election is deemed by paragraph 96(3)(b) to have been made or executed by each other...
22 March 2006 External T.I. 2006-0168491E5 F - Vente de compte-clients et d'achalandage
Regarding the consequences of the sale of a business of a financial securities advisor who provided life insurance policies and other products to...
13 July 1994 External T.I. 9410205 - LOANS NOT ACQUIRED IN THE ORDINARY COURSE...
An election under s. 22 is not available where parts of a business or assets of a business are acquired by a number of purchasers.
The deeming...
17 September 1992 T.I. (Tax Window, No. 24, p. 4, ¶2195)
A taxpayer cannot elect under both ss.85(1) and 22 with respect to accounts receivable.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 15 |
31 August 1992 T.I. 921342 (April 1993 Access Letter, p. 136 ¶C20-1142)
A privately-appointed receiver-manager would be considered to transfer property to a purchaser on behalf of the debtor. Accordingly, it is the...
30 November 1991 Round Table (4M0462), Q. 14.3 - Sale of Debts (C.T.O. September 1994)
In considering a situation where a corporation had two divisions, one of which did printing and the other which did photo typesetting, and all the...
IT-188R Archived "Sale of Accounts Receivable" 22 May 1984
1. Section 22 is applicable upon election by a vendor and a purchaser, where the vendor (individual, partnership, corporation or estate) sells...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 17 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) | 28 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Account Receivable | 173 |
IT-206R "Separate Businesses"
General discussion of what constitutes a separate business.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) | 531 | |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | 344 |
Forms
T2022 "Election in Respect of the Sale of Debts Receivable"
If the vendor or the purchaser is a partnership, a designated partner must sign the...