Words and Phrases - "cost"

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7 October 2011 Roundtable, 2011-0408351C6 F - Honoraire d'évaluation d'une police d'assurance

valuing the FMV of acquired property not considered to be part of its cost

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(1) no deduction from gain for disposition expenses 104

7 October 2011 Roundtable, 2011-0399441C6 F - T1135 - coût indiqué d'une assurance-vie

adjusted cost basis of policy is generally its “cost” under para. (f)

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Reporting Entity cost amount of foreign policy is its adjusted cost basis 82

Devon Canada Corporation v. The Queen, 2018 TCC 170, 2018 TCC 170

payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) quaere whether “sale” includes a sale to a 3rd party 167
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) stock option surrender payments of target deductible under s. 111(5.2) 58
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition of surrendered stock options occurred under doctrine of merger 287
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base "cost" implies the acquisition of an asset 163

24 May 2013 External T.I. 2013-0487581E5 F - Nature d'un bien acquis pour la revente

cost includes costs incurred to bring the inventory item to its current condition and location/meaning of adventure

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Words and Phrases
cost

18 May 2017 Roundtable, 2017-0692361C6 - CLHIA 2017 Q4 - Gift of a life insurance policy

adjusted cost basis of policy is a reasonable proxy for its cost

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(35) - Paragraph 248(35)(b) - Subparagraph 248(35)(b)(i) gifted policy deemed to have its nil adjusted cost basis to the NAL transferor to the donor 287

14 March 2016 Internal T.I. 2015-0609671I7 - Earnout, Amalgamation, Cost of Shares and ECE

earnout payments an addition to cost of shares which had since disappeared

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) post-amalgamation earnout payment could be applied to increase an s. 88(1)(d) bump of capital property (but not ECP) of the amalgamated target 299
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payments made by Amalco in satisfaction of earnout obligation for acquisition of one precedessor by the other were not ECE 204
Tax Topics - General Concepts - Purpose/Intention attribution of predecessor's intention to Amalco 132
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) position on interest deductibility following target amalgamation is based on policy and ITA scheme rather than technical 338

Coast Capital Savings Credit Union v. Canada, 2016 FCA 181

rejection of apparent attempt to argue that an inflated purchase price should be bifurcated between a FMV cost and a benefit conferral

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant 268
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base no bifurcation of inflated purchase price between FMV cost and benefit conferral 132

4 June 2014 External T.I. 2013-0513761E5 - Meaning of "cost" in determining "equity amount"

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Words and Phrases
cost in respect of

The Queen v. Stirling, 85 DTC 5199, [1985] 1 CTC 275 (FCA)

interest and other bullion carrying charges not added

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Words and Phrases
cost

Bodrug Estate v. The Queen, 90 DTC 6521 (FCTD), aff'd 91 DTC 5621 (FCA)

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Words and Phrases
cost

Water's Edge Village Estates (Phase II) Ltd. v. Canada, 2002 DTC 7172, 2002 FCA 291

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 254 - Subsection 254(4) 167
Tax Topics - Income Tax Act - Section 96 exploiting modest business asset was sufficient partnership activity 221
Tax Topics - Statutory Interpretation - Resolving Ambiguity 171
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(3) prompt amendment evidenced intent to end anomaly 82