Words and Phrases - "sale price"
23 March 2011 Internal T.I. 2010-0389081I7 F - Disposition of a resource property
proceeds included full (undiscounted) deferred cash proceeds, but might exclude share consideration (with volatile market price) until issued
The Vendor sold a percentage interest in mineral claims (the “Mining Properties”) for consideration including deferred cash payments and...
Words and Phrases
sale price| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - cumulative Canadian development expense - Element F | proceeds from mineral claims sale included undiscounted deferred cash proceeds, but might exclude share consideration until issued; purchaser’s CEE obligation excluded | 390 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | deferred share consideration potentially not recognized until issuance | 103 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | full undiscounted amount of future cash consideration to be included as an amount receivable | 209 |
Avril Holdings Ltd. v. Minister of National Revenue, 70 DTC 6366, [1970] CTC 572, [1971] S.C.R. 601
proceeds of disposition not reduced to reflect that debentures received had a lower FMV that their principal amount
In rejecting an argument that recapture of depreciation should be reduced to reflect the fair market value of debentures received in consideration...
Words and Phrases
sale price| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule V | 69 | |
| Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) | proceeds of disposition based on face amount rather than FMV of debentures received therefor | 66 |