Cases
Pantorama Industries Inc. v. Canada, 2005 FCA 135
In finding that the variable components of fees paid by the taxpayer (“Snowcap”), which sold casual clothing through a chain of retail stores...
See Also
Ressources Eastmain Inc. v. Agence du revenu du Québec, 2021 QCCQ 4379
In finding that the recurring costs of racks and boxes incurred by an exploration company in order to store core samples were capital...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1206 - Subsection 1206(1) - Canadian exploration and development overhead expense - Paragraph (b) | as a junior exploration company’s CEO devoted "substantially all" (75%) of his time to exploration, his salary was not CEDOE | 283 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (k.1) | annual expenditures on core sample boxes and racks were excluded under para. (k.1) | 105 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | geology course for an employee was necessary to exploration and resource identification | 173 |
Commissioner of Taxation v Healius Ltd, [2020] FCAFC 173
A subsidiary (“Idameneo”) of an Australian public company provided medical centre facilities and services to doctors in consideration for 50%...
Administrative Policy
9 February 2022 Internal T.I. 2020-0873931I7 - Cover Letter - Mining Expenditure Review Table
Pre-feasibility and feasibility studies generally give rise to deductions under s. 9.
The following are deductible under s. 9 if incurred before...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | listing of various qualifying (and non-qualifying) items | 409 |
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Canadian development expense - Paragraph (e) | mineral claims and exploration permits included | 21 |
17 February 2010 Internal T.I. 2009-0348461I7 F - Transfert d'une PCMC à une société mère
After a subsidiary (“Imageco”) of a Canadian-controlled private corporation (“Canco”) produced a film and DVD (the "CFVPs"), being...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 10 - Paragraph 10(x) | full cost of CFVPs acquired by parent from production sub (which claimed the credits) added to Class 10(x) | 88 |
29 July 2004 Internal T.I. 2004-0065971I7 F - Frais d'intégration de sociétés
After Bco, the parent of Aco, entered into an agreement to acquire two corporations, but before those corporations were acquired, Aco started...
14 May 2001 Internal T.I. 2001-0065717 F - PAIEMENT INCITATIF REVENUE DE LOCATION
CCRA indicated that tenant inducements made by a landlord in the form of building additions or improvements to the rented premises were...
30 June 2000 Internal T.I. 2000-0029917 F - Dépense en capital - arbres fruitiers
Archambault v. The Queen, 2000 DTC 1809 found, consistent with the Agency position, that the costs of planting new apple trees were capital...