Brown v. The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA) -- summary under A

By services, 28 November, 2015

Rip T.C.J. accepted the position of the Minister that a note issued by a partnership as part of the consideration for the purchase by it of software "engines" was a contingent note because interest and principal on it were payable only out of stipulated percentages of gross profits generated by the software. Accordingly, the capital cost of the software did not include the amount of the note.

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Drupal 7 entity ID
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