Capital Management Ltd. v. MNR, 68 DTC 5041, [1968] CTC 29 (SCC) -- summary under Class 14

By services, 28 November, 2015

The taxpayer purchased, from an affiliated company, the right to manage two mutual funds (which would entitle it to earn a quarterly fee of 1/8 of 1% of their assets) together with the right to designate selling agents for the sale of shares of the mutual funds and to receive a 2% acquisiton fee on such sales. In dismissing th etaxpayer's position that the purchase price of $1.9 million was depreciable as the capital cost of a Class 14 asset, Spence J stated his agreement with the Investor's Group case.

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