CIT Financial Ltd. v. Canada, 2004 DTC 6573, 2004 FCA 201 -- summary under Other

By services, 28 November, 2015

The Tax Court Judge did not err in finding that the replacement cost method was the best way to value software that specifically had been designed to run a particular steel mill. An alternative valuation based on the present value of lease payments to be received for the rental of the software in a non-arm's length transaction was flawed as the lease payments were based on a faulty (and excessive) valuation of the software.

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