Subtopics
Cases
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336, [1998] 1 CTC 213
On the winding-up of its wholly-owned subsidiary, the taxpayer received heavy equipment that had been used in the subsidiary's leasing business....
See Also
Thibeault v. The Queen, 2015 TCC 271
In finding that the taxpayer was precluded by the preamble to s. 20(1) from deducting CCA respecting boats which he no longer was leasing,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17.3) | bare boat lease by individual did not qualify as business activity | 165 |
Administrative Policy
11 October 2019 APFF Roundtable Q. 2, 2019-0812611C6 F - Résiliation d'un bail - Lease cancellation
A tenant had been annually renewing a lease of a personal-use condo since the time the condo was first leased in July 2013. The condo was sold in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(z) | s. 20(1)(z) applies notwithstanding s. 18(1)(a) but is subject to source rule in s. 20(1) preamble | 193 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) | lease termination payment received by tenant was referable to complete period of holding of (annually renewed) leasehold interest | 245 |
| Tax Topics - Income Tax Act - Section 54 - Principal Residence | lease termination payment received by tenant was eligible for principal residence exemption | 116 |
22 June 2015 Internal T.I. 2014-0553731I7 - Deduction of Terminal Loss - Wind-up
A corporation ("Parentco") received depreciable property of its subsidiary on a s. 88(1) winding-up with no intention of using the property for an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a) | property remaining idle after deemed acquisition as depreciable property not a change of use | 176 |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) | depreciable property of sub deemed to be depreciable property when acquired by parent | 444 |
5 March 2012 Internal T.I. 2010-0384681I7 - Preamble to subsection 20(1) of the Income Tax Act
the applicable-to-source test in the preamble "requires that expenses described in paragraphs 20(1)(a) - (ww) of the Act must be prorated between...
7 October 2011 Roundtable, 2011-0412061C6 F - Financing Expenses
If an issuer intends only to realize capital gains from its investments, would its issue expenses be deductible under the s. 20(1)(e)(i)? CRA...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) | no s. 20(1)(e) deduction if only capital property that is not a source of income | 101 |
2003 Ruling 2003-001372
Favourable rulings given with respect to transactions for the transfer of losses of a parent public corporation to its profitable subsidiary...
7 March 2001 Internal T.I. 2001-007215
A taxpayer will be entitled to deduct over time the entire amount of the cost of depreciable property notwithstanding that such property,...
2000 Ruling 2000-0038963 - Affiliated group of persons loss ATIL
Depreciable assets transferred on a rollover basis to a wholly-owned subsidiary which then amalgamated were acquired by it for the purpose of...
5 June 1997 Internal T.I. 9704727 - SPECIAL WARRANT ISSUE COSTS
After referring, with respect to a question as to the deductibility of issue expenses incurred for special warrants, to the requirements in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | 16 |