McCoy v. The Queen, 2003 DTC 660, 2003 TCC 332 -- summary under Paragraph 1102(1)(c)

By services, 28 November, 2015

Before going on to find that a limited partnership had acquired software for the purpose of gaining or producing income, Bowman A.C.J. stated (at p. 678):

"Intention is subjective. Purpose, while it may involve a subjective element, must be largely determined on the basis of objective considerations. It is impossible if one looks at the material that was presented to the investors to conclude that the earning of income was not a purpose of the partnership."

Topics and taglines
Topic
Income Tax Regulations - s. 1102(1)(c)
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339882
Extra import data
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