Cases
Steeves v. The Queen, 77 DTC 5230 (FCA)
At the same time as the taxpayer and his brother purchased the remaining 50% of the common shares of a road-paving company in financial difficulty...
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Debt/ receivables | 107 |
Terminal Dock and Warehouse Co. Ltd. v. MNR, 68 DTC 5060, [1968] CTC 78 (Ex Ct), aff'd 68 DTC 5316 (SCC)
One of the activities of the taxpayer, whose main business was that of a dock and wharfage company, was to finance the purchase of shares in its...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | advances to employees on capital account | 120 |
Ted Davy Finance Co. Ltd. v. MNR, 64 DTC 5124, [1964] CTC 194 (Ex Ct)
Proceeds received by the taxpayer, which carried on the business of purchasing conditional sales contracts (mostly from a related used car dealer)...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | conditional sales contracts not invenory | 75 |
See Also
No. 570 v. MNR, 58 DTC 617 (TAB)
The taxpayer was one of 13 partners in a firm of chartered accountants that sold the practice to another firm, including a sale of the...
Crompton v. Reynolds and Gibson, [1952] 1 All E.R. 888, [1952] UKHL TC (HL)
Four successive partnerships (referred to as firms Nos. 1, 2, 3 and 4) carried on business as cotton brokers. Firms Nos. 1 and 2 were deemed to be...
Administrative Policy
30 November 1999 Income Tax Severed Letter 9M19160 - QUE. REGION TECH. ADVISORS CONF.
When a corporation sells its accounts receivable at a discount to a financial institution or an entity whose main activity consists in managing...
1993 A.P.F.F. Round Table, Q.14 (Windows File No. 3M09520)
"The disposition of trade receivables does not normally result in a capital gain or loss ... . However, a taxpayer's trade receivables are...
3 December 1993 External T.I. 9200995 F - Transfer of Farm Inventory to a Corporation
Since the entitlement of a farmer under a gross revenue insurance program constitutes an account receivable to him that relates to the farming...
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| Tax Topics - General Concepts - Fair Market Value - Other | 66 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | 59 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 51 |
30 July 1992 Income Tax Severed Letter 9218715 - Cost Amount - Accounts Receivable
Accounts receivable usually will be regarded as capital property except where the taxpayer is a trader in accounts receivable.
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Cost Amount | 36 |
3 June 1992 Income Tax Severed Letter 9130405 - Intercorporate Debt on Amalgamation
A trade debt held by a creditor is considered to be capital property unless the creditor corporation is in the business of lending money....
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) (old) | 73 |
1 August 1991 Ministerial Letter 911898 F - Trade in Securities
Neither the assignment of accounts receivable to a creditor finance company nor the holding of receivables acquired in the ordinary course of...
4 April 1991 Internal T.I. 7-902723
Whether the amount realized by the vendor corporation in a receivables securitization is deductible by it turns on whether the arrangement is a...
IT-188R Archived "Sale of Accounts Receivable" 22 May 1984
Sale or purchase of trade receivables as part of business on capital account
7. If the sale of accounts receivable by taxpayers on the accrual...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) | 116 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) | 17 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) | 28 |
IT-442R "Bad Debts and Reserves for Doubtful Debts"
Deductibility of bad debt losses on ordinary principles
1. ...[W]here...a debt was of a kind that would have qualified for consideration as a bad...
Commentary
The principle that the purchase (or sale) of all or substantially all the assets of a business occurs on capital account except to the extent that...