goodwill

Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1
operating agreement of care facility with province was goodwill because it could not be transferred without a transfer of the care business

On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Actuarial Surplus
CRA finds that the purchase price of a business allocated to the actuarial surplus for a defined benefit plan was a non-deductible capital expenditure

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill reserve

Healius Ltd v Commissioner of Taxation, [2019] FCA 2011, rev'd [2020] FCAFC 173 -- summary under Contract Purchases or Prepayments

Full Title
Healius Ltd v Commissioner of Taxation, [2019] FCA 2011, rev'd [2020] FCAFC 173
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract Purchases or Prepayments
lump sum payments made to lock-up doctors as customers for a 5-year period were currently deductible

The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill

Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36 -- summary under Paragraph 13(34)(b)

Full Title
Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36
Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(34) - Paragraph 13(34)(b)
10-year gaming licences required to maintain existing gaming revenues were not for goodwill

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill

Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59 -- summary under Paragraph (a)

Full Title
Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 - Paragraph (a)
goodwill must have a connection to attracting custom

Whether the acquisition by Barrick Gold Corporation ("Barrick") of another Canadian public company, namely, Placer Dome Inc. ("Placer") triggered...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill

Lupien v. The Queen, 2016 TCC 2 -- summary under Other

Full Title
Lupien v. The Queen, 2016 TCC 2
Summary Under
Tax Topics - General Concepts - Fair Market Value - Other
distributor earning significant relative profits had no transferable goodwill where no evidence of long-term distributorship agreement

A lacquer-manufacturing corporation (“Antoni”) indirectly owned by the taxpayer’s brother imported one of its product lines from an Italian...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill

Transalta Corporation v. Canada, 2012 DTC 5040 [at at 6757], 2012 FCA 20 -- summary under Section 68

Full Title
Transalta Corporation v. Canada, 2012 DTC 5040 [at at 6757], 2012 FCA 20
Summary Under
Tax Topics - Income Tax Act - Section 68
parties' allocation to goodwill respected

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 text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill

The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA) -- summary under Cumulative Eligible Capital

Full Title
The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
goodwill
Subscribe to RSS - goodwill