Words and Phrases - "goodwill"

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

operating agreement of care facility with province was goodwill because it could not be transferred without a transfer of the care business

On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 14 - Subsection 14(1.01) cost of property acquired can be nil 113

28 January 2021 Internal T.I. 2019-0817641I7 - Acquisition of rights to pension surplus

CRA finds that the purchase price of a business allocated to the actuarial surplus for a defined benefit plan was a non-deductible capital expenditure

A portion of the purchase price paid for the acquisition of a business of the Seller by the Purchaser was allocated to the actuarial surplus in a...

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Words and Phrases
goodwill reserve
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) purchased actuarial surplus was a reserve 195
Tax Topics - Income Tax Act - Section 78 - Subsection 78(4) s. 78(4) exclusion would apply to the purchase of actuarial surplus 191
Tax Topics - Income Tax Act - Section 13 - Subsection 13(35) purchased actuarial surplus was not deemed goodwill under s. 13(35) 222

Healius Ltd v Commissioner of Taxation, [2019] FCA 2011, rev'd [2020] FCAFC 173

lump sum payments made to lock-up doctors as customers for a 5-year period were currently deductible

The taxpayer was an Australian public company that provided (including, relevantly, through a subsidiary trust (“Idameneo”) whose results were...

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Words and Phrases
goodwill

Commissioner of Taxation v Sharpcan Pty Ltd, [2019] HCA 36

10-year gaming licences required to maintain existing gaming revenues were not for goodwill

Due to a regulatory change, a hotel owner which had been sharing in the revenues generated from 18 gaming machines on its premises was required to...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract Purchases or Prepayments 10-year gaming licences required to maintain existing gaming revenues were purchased on capital account 350
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Concessions and Licences periodic payments under 30-year government concession were currently deductible 206
Tax Topics - General Concepts - Purpose/Intention purpose distinguished from motive 237

Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59

goodwill must have a connection to attracting custom

Whether the acquisition by Barrick Gold Corporation ("Barrick") of another Canadian public company, namely, Placer Dome Inc. ("Placer") triggered...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Other discounted cash flow valuation undervalued resource lands and residual valuation overstated goodwill 342
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property protean nature of property concept 491

Lupien v. The Queen, 2016 TCC 2

distributor earning significant relative profits had no transferable goodwill where no evidence of long-term distributorship agreement

A lacquer-manufacturing corporation (“Antoni”) indirectly owned by the taxpayer’s brother imported one of its product lines from an Italian...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) double application of s. 160 re asset sale for excess consideration 92

Transalta Corporation v. Canada, 2012 DTC 5040 [at 6757], 2012 FCA 20

parties' allocation to goodwill respected

A partnership bought the assets of an electric company at a price that was $190 million in excess of the regulated book value (the amount on which...

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Words and Phrases
goodwill

The Queen v. Demco Management Ltd., 85 DTC 5603, [1986] 1 CTC 92 (FCA)

Mahoney, J. stated that a definition of the goodwill of a private hospital "should bear in mind that the basis of its worth was its power to...

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 68 54