Words and Phrases - "goodwill"
9 November 2005 Internal T.I. 2005-0154301I7 F - Choix concernant les immobilisations admissibles
On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec...
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| Tax Topics - Income Tax Act - Section 14 - Subsection 14(1.01) | cost of property acquired can be nil | 113 |
28 January 2021 Internal T.I. 2019-0817641I7 - Acquisition of rights to pension surplus
A portion of the purchase price paid for the acquisition of a business of the Seller by the Purchaser was allocated to the actuarial surplus in a...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | purchased actuarial surplus was a reserve | 195 |
| Tax Topics - Income Tax Act - Section 78 - Subsection 78(4) | s. 78(4) exclusion would apply to the purchase of actuarial surplus | 191 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(35) | purchased actuarial surplus was not deemed goodwill under s. 13(35) | 222 |
Healius Ltd v Commissioner of Taxation, [2019] FCA 2011, rev'd [2020] FCAFC 173
The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were...
Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36
Due to a regulatory change, a hotel owner which had been sharing in the revenues generated from 18 gaming machines on its premises was required to...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract Purchases or Prepayments | 10-year gaming licences required to maintain existing gaming revenues were purchased on capital account | 350 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Concessions and Licences | periodic payments under 30-year government concession were currently deductible | 206 |
| Tax Topics - General Concepts - Purpose/Intention | purpose distinguished from motive | 237 |
Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59
Whether the acquisition by Barrick Gold Corporation ("Barrick") of another Canadian public company, namely, Placer Dome Inc. ("Placer") triggered...
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| Tax Topics - General Concepts - Fair Market Value - Other | discounted cash flow valuation undervalued resource lands and residual valuation overstated goodwill | 342 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | protean nature of property concept | 491 |
Lupien v. The Queen, 2016 TCC 2
A lacquer-manufacturing corporation (“Antoni”) indirectly owned by the taxpayer’s brother imported one of its product lines from an Italian...
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| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | double application of s. 160 re asset sale for excess consideration | 92 |
Transalta Corporation v. Canada, 2012 DTC 5040 [at 6757], 2012 FCA 20
A partnership bought the assets of an electric company at a price that was $190 million in excess of the regulated book value (the amount on which...
The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA)
Mahoney, J. stated that a definition of the goodwill of a private hospital "should bear in mind that the basis of its worth was its power to...
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| Tax Topics - Income Tax Act - Section 68 | 54 |