Manrell v. The Queen, 2002 DTC 1222 (TCC), rev'd 2003 DTC 5225, 2003 FCA 128 -- summary under Disposition

By services, 28 November, 2015

The taxpayer and corporations controlled by him disposed of shares of three corporations engaged in manufacturing plastic moulds and caps and received, in addition to sale proceeds for the shares, lump sums (payable in instalments) in consideration for giving non-compete covenants.

McArthur T.C.J. characterized the non-compete payments as consideration for the disposition of the right to compete with the purchaser, with the result that they represented capital gains.

Topics and taglines
Topic
Income Tax Act - s. 248(1) - Disposition
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
337164
Extra import data
{
"field_legacy_header": "<strong><em>Manrell v. The Queen</em></strong>, 2002 DTC 1222, Docket: 1999-2167-IT-G (TCC), rev'd 2003 DTC 5225, 2003 FCA 128",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}
Workflow properties
Workflow state
Publish with parent