Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147, [1998] 2 C.T.C. 35 -- summary under Onus

By services, 28 November, 2015

In the course of finding that a taxpayer, which amortized tenant inducement payments for financial statement purposes, was entitled to immediately expense those payments for tax purposes, Iacobucci J. stated (at p. 6100):

"On reassessment, once the taxpayer has shown that he has provided an accurate picture of income for the year, which is consistent with the Act, the case law, and well-accepted business principles, the onus shifts to the Minister to show either that the figure provided does not represent an accurate picture, or that another method of computation would provide a more accurate picture."

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