Given that the trial judge had made a finding that the primary purpose of the taxpayer in making two payments to or for the benefit of two tenants was to induce them to lease space in the building, the matching principle could not be applied because there was no linkage to future revenue. (If the matching principle had been applicable, the payments would have been amortized only over the terms of the leases, and not any renewal periods). Because the Minister had not persuaded the Court that the amortization of the payments would present even as accurate a picture of income as the method adopted by the taxpayer (current deduction of the full amount of the payments), the taxpayer was entitled to deduct the payments entirely in the year they were made.
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Tagline
tenant inducement payments currently deductible as no linkage to future revenue
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339598
Extra import data
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"field_legacy_header": "<strong><em><a name=\"CollegePark\"></a>Toronto College Park Ltd. v. The Queen</em></strong>, [1998] 1 S.C.R. 183 <strong>[tenant inducement payments currently deductible as no linkage to future revenue]</strong>",
"field_override_history": false,
"field_sid": "",
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}
"field_legacy_header": "<strong><em><a name=\"CollegePark\"></a>Toronto College Park Ltd. v. The Queen</em></strong>, [1998] 1 S.C.R. 183 <strong>[tenant inducement payments currently deductible as no linkage to future revenue]</strong>",
"field_override_history": false,
"field_sid": "",
"field_topic_category": ""
}