Minister of National Revenue v. Imperial Oil Co., 60 DTC 1219, [1960] CTC 275, [1960] S.C.R. 735 -- summary under Timing

By services, 28 November, 2015

In computing its "profits ... reasonably attributable to the production of oil or gas", the taxpayer treated oil delivered by its producing department to other departments and still unsold at the end of the year as having been sold by the producing department at a profit. In rejecting this method, Judson J. stated (p. 1224):

"In fact, the producing department was not a separate entity for tax purposes ... No company makes an actual profit merely by producing oil. There is no profit until the oil is sold."

Topics and taglines
Topic
Income Tax Act - s. 9 - Timing
Tagline
no profit from intra-company sale
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339570
Extra import data
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