Dalron Construction Limited v. The Queen, 2008 DTC 4733, 2008 TCC 476 -- summary under Real Estate

By services, 28 November, 2015

Land transferred by the taxpayer (whose business was the purchase and development of land through the construction of residential and commercial buildings) to a subsidiary that was 80% owned by it occurred on income account (so that the joint election made under s. 85 was invalid) given that at its previous year ends it had treated the land as inventory and given that there was no evidence that it had used the land for any commercial purpose.

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