cost

Devon Canada Corporation v. The Queen, 2018 TCC 170 -- summary under Eligible Capital Expenditure

Full Title
Devon Canada Corporation v. The Queen, 2018 TCC 170
Summary Under
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure
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...

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Words and Phrases
cost
Summary Under
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1.01)
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...

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Words and Phrases
cost
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(36)
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)...

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Words and Phrases
cost
Summary Under
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base
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...

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Words and Phrases
cost

Coast Capital Savings Credit Union v. Canada, 2016 FCA 181 -- summary under Subsection 116(5)

Full Title
Coast Capital Savings Credit Union v. Canada, 2016 FCA 181
Summary Under
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5)
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.

Words and Phrases
cost
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Equity Amount - Paragraph (c)
"cost" not reduced by amortization

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

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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) -- summary under Adjusted Cost Base

Full Title
Bodrug Estate v. The Queen, 90 DTC 6521, [1990] 2 CTC 324 (FCTD), aff'd 91 DTC 5621 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base

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...

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Words and Phrases
cost

The Queen v. Stirling, 85 DTC 5199, [1985] 1 CTC 275 (FCA) -- summary under Adjusted Cost Base

Full Title
The Queen v. Stirling, 85 DTC 5199, [1985] 1 CTC 275 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base
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...

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Words and Phrases
cost

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

Full Title
Water's Edge Village Estates (Phase II) Ltd. v. Canada, 2002 DTC 7172, 2002 FCA 291
Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A
cost means original cost

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

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Words and Phrases
cost

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

Full Title
Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A
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...

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Words and Phrases
cost

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