Sivasubramaniam v. The Queen, 2008 DTC 3886, 2008 TCC 261 (Informal Procedure) -- summary under Paragraph 1102(1)(b)

By services, 28 November, 2015

The taxpayer argued that his rental condominium units were not rental properties because they had been acquired by him with a view to their resale at a capital gain. Bowman C.J. noted that such an intention would be inconsistent with claiming capital cost allowance. He also noted (at para. 9) that although property held for sale might not be "described" in the taxpayer's inventory, "the short answer, I believe, is that paragraph 1102(1)(c) is probably unnecessary" given that property that was inventory, whether or not described in a list called an inventory, would not be eligible for a capital cost allowance as it would not have a capital cost.

Topics and taglines
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339873
Extra import data
{
"field_legacy_header": "<strong><em>Sivasubramaniam v. The Queen</em></strong>, 2008 DTC 3886, 2008 TCC 261",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}