Words and Phrases - "receivable"
5 January 2001 Internal T.I. 2000-0053767 F - IT-92R2 Paragraphe 1
In finding that construction holdbacks by a subcontractor did not become receivable until their release was approved by the architect or engineer,...
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Tax Topics - Income Tax Act - Section 9 - Timing | progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner | 315 |
20 December 2002 External T.I. 2002-0164735 F - PRODUIT DE DISPOSITION ACHALANDAGE
On a sale of the business of a pharmacist, the goodwill value of $750,000 (payable in 72 equal monthly instalments) is based on the number of...
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | s. 12(1)(g) applicable to incremental pharmacy sales price for goodwill based on volume of prescriptions for post-sale years | 110 |
9 July 2003 External T.I. 2003-0183675 F - VENTE D'UNE LISTE DE CLIENTS
In one of the alternative scenarios for the sale of the client list of a retiring professional, the sale price is 25% of the fees earned over the...
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | application of s. 12(1)(g) only to excess participating sales price for client list over minimum, or where there is a maximum equaling the client list’s FMV | 369 |
Midwest Oil Production Ltd. v. The Queen, 82 DTC 6092, [1982] CTC 107 (FCTD), aff'd 83 DTC 5304, [1983] CTC 338 (FCA)
Because the word "receivable" relates to a change in custody or possession, not to a change in ownership, a royalty obligation to deliver crude...
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Tax Topics - Income Tax Act - Section 169 | 57 | |
Tax Topics - Income Tax Act - Section 172 - Subsection 172(2) | 57 | |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Amount | 17 |
MNR v. Colford Contracting Co. Ltd., 60 DTC 1131, [1960] CTC 178 (Ex Ct), briefly aff'd 62 DTC 1338, [1962] CTC 546 (SCC)
Holdbacks on contracts for the installation of heating and plumbing systems became "receivable" when the architect's or engineer's certificates...
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Tax Topics - Income Tax Act - Section 9 - Timing | 25 |
Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct)
Cameron, J. held that the full amounts covered by interim progress certificates of the supervising engineer became "receivable" for the purposes...
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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 15 | |
Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 25 | |
Tax Topics - Income Tax Act - Section 9 - Timing | 142 |