Words and Phrases - "for the purpose"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

15 October 2015 Internal T.I. 2014-0527041I7 F - Disposition de biens

Summary Under
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i)
merely facilitative expenses not deducible

In the course of a discussion not based on a repetition of the applicable facts, CRA stated:

...Avis Immobilien GMBH ... [found that] "for the purpose of" in subparagraph 40(1)(a)(i) means the immediate or initial purpose and not the eventual or final goal...[and] only the outlays and expenses incurred or made directly for the purpose of making the disposition of the property are considered in subparagraph 40(1)(a)(i), and not those which may have merely facilitated the disposition. The CRA is of the view that these principles established for the purposes of subparagraph 40(1)(a)(i) also apply to subparagraph 40(1)(b)(i).

Words and Phrases
for the purpose