Words and Phrases - "cost"

77
38
66
45
31
30
16
10
68
2
2
30
48
22
35
75
2
69
74
44
12
8
19
2

Teleglobe Canada Inc. v. R., 2002 DTC 7517, 2002 FCA 408

cost of assets acquired was the stated capital of the shares issued therefor, being the agreed transaction value

In connection with a privatization transaction and at a time that it was still owned by the federal Crown, the taxpayer purchased assets for 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
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital cost of assets purchased with treasury shares was the agreed purchase price being the shares’ stated capital 238

9 November 2005 Internal T.I. 2005-0154301I7 F - Choix concernant les immobilisations admissibles

cost of property acquired can be nil

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
cost
Locations of other summaries Wordcount
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 232

9 March 2020 External T.I. 2013-0490301E5 F - Société exploitant une EPSP

PSB can deduct for auto leasing costs or loan interest expense to extent of benefit conferred on the individual qua employee rather than shareholder – but no CCA deduction (other than under s. 18(1)(p)(iii))

Is a corporation carrying on a personal services business ("PSB") entitled to deduct the following under s. 18(1)(p)(ii): (i) the costs of leasing...

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
cost

Lee v. Agence du revenu du Québec, 2020 QCCQ 780, aff'd sub nomine Seica v. Agence du revenu du Québec, 2021 QCCA 1401

tax shelter definition applied on a property-by-property basis, and cost excluded interest

A tax shelter, for the initial (2003/2004) years assessed by the ARQ, entailed the sale by a corporation (“Prospector”) to over 200 investors...

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
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest on limited recourse notes that could be extinguished through the surrender of the limited recourse asset was deductible 226
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(6) limited recourse debt eliminated CCA claims 151

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

An actuary is retained to determine the fair market value of a life insurance policy by an individual to a wholly-owned corporation, and the...

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
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 148 - Subsection 148(1) no deduction from gain for disposition expenses 110

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)

The definition of reporting entity in s. 233.3 references its “cost amount” of specified foreign property. Is the cost amount of an interest...

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
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 88

Devon Canada Corporation v. The Queen, 2018 TCC 170

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

Two public-company predecessors by amalgamation of the taxpayer made cash payments for the surrender by employees of their options previously...

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
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 177
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) stock option surrender payments of target deductible under s. 111(5.2) 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition of surrendered stock options occurred under doctrine of merger 318
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base "cost" implies the acquisition of an asset 172

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

In the context of a general discussion of s. 10(1.01) respecting a car acquired and repaired with a view to its sale at a profit, CRA stated:

The...

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
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

Mr. A acquired a life insurance policy on his life with a $1 million death benefit and then transferred it to his wholly-owned corporation (ACo)...

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
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 301

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

A Canadian Acquisitionco acquired Canadian Targetco for a cash base price plus earnout obligations, and then immediately merged with Targetco...

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
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 317
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 224
Tax Topics - General Concepts - Purpose/Intention attribution of predecessor's intention to Amalco 140
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 350

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

The applicant (“Coast Capital”), which was the trustee of RRSPs and RRIFs, was assessed under s. 116(5) for failure to withhold on its...

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
cost
Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant 282
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base no bifurcation of inflated purchase price between FMV cost and benefit conferral 142

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

Generally, … the "cost" of property …include[s] the amount laid down to acquire such property. … The Queen v. Canada Trustco Mortgage...

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
cost in respect of

Bodrug Estate v. The Queen, 90 DTC 6521, [1990] 2 CTC 324 (FCTD), aff'd 91 DTC 5621 (FCA)

An estate paid $1,320,000 to settle an action brought against it by two other persons ("Cohen" and "NIR") for specific performance of an option...

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
cost

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

interest and other bullion carrying charges not added

The word "cost" in s. 54(a) "means the price that the taxpayer gave up in order to get the asset; it does not include any expense that he may have...

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
cost

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

In December 1991 the taxpayers (who were Canadian residents) acquired most of the partnership interests in a U.S. partnership ("Klink") that had...

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
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 254 - Subsection 254(4) 177
Tax Topics - Income Tax Act - Section 96 exploiting modest business asset was sufficient partnership activity 229
Tax Topics - Statutory Interpretation - Resolving Ambiguity 179
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(3) prompt amendment evidenced intent to end anomaly 88

Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (FCA)

cost not reduced by reimbursement right therefor

Amounts expended by the taxpayer to install new pipelines were additions to the capital cost of its depreciable assets notwithstanding that it was...

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
cost