FEB 1 1989
TO Current Amendments and Regulations Division
B. Bryson A/Director
FROM Small Business and General Division R. Langevin 957-2138
SUBJECT: Sale of Players' Contracts
of Professional Sports ClubsThis is in reply to your memorandum dated December 15, 1988, concerning the tax treatment afforded purchasers and sellers of players's [sic] contracts of professional sports clubs.
It has been our view that on the purchase of a team such contracts may be written off against income inasmuch as the sale price of the contract to the purchaser is permitted to be amortized. Upon the sale of the team, the proceeds of such contracts are treated as being on capital account. However, both the purchase and sale of an individual contract are charged or credited directly to income account.
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M.A.G. Hiltz Acting Director General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch
[Handwritten: Jan. 31/89 Phoned B. Bryson and relayed this information to him. He said a written reply was not necessary. W. McColm]