Roth v. The Queen, 2005 DTC 1570, 2005 TCC 484, aff'd 2007 DTC 5222, 2007 FCA 38 -- summary under Incurring of Expense

By services, 28 November, 2015

The purported transfer by the taxpayer of an undeveloped project (i.e., of know-how he had developed with respect to a proposed LNG project) was not documented with any conveyance document and, in any event, "information, ideas, knowledge and/or know-how do not fall within the meaning of the word 'property'" (p. 1579). As the transferee corporation had not acquired anything from the taxpayer (know-how not being included in the meaning of the word property), a journal entry showing $370,000 owing by it to the taxpayer for the purported transfer did not represent an expense incurred by it.

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purported transfer of knowhow to corportion did not entail acquisition of property
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