Words and Phrases - "sale"
29 May 2024 External T.I. 2019-0819561E5 F - Catégorie d’amortissement 53 de l’Annexe II du Règlement
Equipment was acquired by a corporation (“Aco”), wholly-owned by a dental surgeon, to manufacture dental restorative products for use as part...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | having equipment owned separately from the services business in which its product is used could permit the manufactured product to be “sold” to the services business | 184 |
20 July 2001 External T.I. 2001-0087205 F - BAIL TRAITEMENT DU PRENEUR
In providing background on the announcement in Income Tax Technical News No. 5 of the withdrawal of IT-233, CCRA stated:
[T]he purpose of the...
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| Tax Topics - General Concepts - Substance | distinction between a sale and a lease is based on the legal terms of the arrangement | 199 |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(5) | whether a lessee has ownership of a building under an emphyteutic lease is a question of law | 117 |
Pharma Coréalis Inc. v. Agence du revenu du Québec, 2023 QCCQ 156
The taxpayer (Coréalis) which, in addition to performing R&D services, entered into “service agreements” with pharmaceutical companies (the...
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| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) - Subparagraph (c)(i) | putting drug companies' active ingredients into capsule form for clinical testing qualified as manufacturing for sale | 289 |
Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068
The taxpayer received organic sludge from suppliers in the agri-food industry, and was paid by them for taking over the sludge, which it then...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | a taxpayer made sales of partially processed waste when it paid other processors to complete its processing | 354 |
12 November 2019 External T.I. 2019-0822161E5 F - T5008 Statement of Securities Transactions
During the 2019 calendar year, Mr. X withdrew the minimum amount (as defined in subsection 146.3(1)) from his RRIF ($5,000 – so that a T4RIF...
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| Tax Topics - Income Tax Regulations - Regulation 230 - Subsection 230(2) | transfer of listed shares from taxable brokerage account to individual’s TFSA did not generate T5008 reporting requirement | 65 |
Stark International Inc. v. The Queen, 2019 TCC 248
The taxpayer (“Stark”) used three newly-constructed transformer maintenance trailers (which were 50-foot trailers (“TMT 3, TMT 4 and TMT...
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| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) | a use test could be applied by looking beyond the property’s immediate intended use | 235 |
Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC)
A predecessor of the defendant (“BC Tel”) raised $150 million by transferring receivables to a securitization trust (“RAC”) in...
11 June 2013 STEP Roundtable Q. 9, 2013-0480351C6 - STEP CRA Roundtable Q9 - June 2013
Respecting whether CRA accepted Sommerer, it stated that the decision stood:
for the general proposition that where property is transferred to a...
Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)
The taxpayer, which paved driveways, parking lots and small roadways, also operated an asphalt-producing plant. 75% of the output was utilized in...
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| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 11 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | word sale should be accorded its private law meaning | 67 |
Renaud v. The Queen, 2010 DTC 1094 [at 2994], 2010 2010 TCC 76
The taxpayer made an eligible relocation to a residence in another town. Rather than sell his old residence, he rented it, which effected a...
Home Provisioners (Manitoba) Ltd. v. MNR, 58 DTC 1183, [1958] CTC 334, [1958] CTC 333 (Ex Ct)
The taxpayer, which sold refrigerators under conditional sales contracts requiring a 10% down payment and the balance payable in 24 monthly...
C.R.I. Environnement Inc. c. La Reine, 2008 DTC 3787, 2007 TCC 206, aff'd 2008 DTC 2471, 2008 FCA 103
The taxpayer, who in consideration for a charge made by it to its customers, sorted, consolidated and reshipped industrial waste produced by them,...