sale

29 May 2024 External T.I. 2019-0819561E5 F - Catégorie d’amortissement 53 de l’Annexe II du Règlement -- summary under Class 53

Equipment was acquired by a corporation (“Aco”), wholly-owned by a dental surgeon, to manufacture dental restorative products for use as part of its dental services.

Alternatively, the surgeon could incorporated a second wholly-owned corporation (“Bco”) to acquire the equipment and sell, to Aco, the dental restorative products it manufactured using the equipment.

By services, 11 July, 2021

Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068 -- summary under Consideration

The taxpayer received organic sludge from suppliers in the agri-food industry, and was paid by them for taking over the sludge, which it then treated and transformed, using electricity, into residual fertilizer materials ("RFM"). It then paid companies (the "Receivers") to acquire the RFM, which they recovered for composting, agricultural land application or as an energy source. It profited by paying significantly less to the Receivers than it received from its sludge suppliers.

12 November 2019 External T.I. 2019-0822161E5 F - T5008 Statement of Securities Transactions -- summary under Sale

During the 2019 calendar year, Mr. X withdrew the minimum amount (as defined in subsection 146.3(1)) from his RRIF ($5,000 – so that a T4RIF slip is issued to him for $5,000), and effected the withdrawal through the transfer to his regular brokerage account at a licensed securities dealer of 100 common shares of a public corporation with a fair market value at the time of transfer of $5,000.

By services, 5 November, 2019

Stark International Inc. v. The Queen, 2019 TCC 248 -- summary under Class 29

The taxpayer (“Stark”) used three newly-constructed transformer maintenance trailers (which were 50-foot trailers (“TMT 3, TMT 4 and TMT 5”) to purify oil, on site, from electrical transformers and also to purify oil at its Nova Scotia premises for subsequent resale. Furthermore, it had constructed a building (the “Fabrication Shop”) used for the construction of TMTs.

By services, 10 December, 2015

Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC) -- summary under Ownership

A predecessor of the defendant (“BC Tel”) raised $150 million by transferring receivables to a securitization trust (“RAC”) in consideration for an advance and the receipt of deferred amounts. RAC funded its payments in the commercial paper market and BC Tel serviced the receivables for no fee.

By services, 28 November, 2015

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 SCR 915 (SCC) -- summary under Class 29

The taxpayer, which paved driveways, parking lots and small roadways, also operated an asphalt-producing plant. 75% of the output was utilized in that paving business, and the balance was sold to third parties. In finding that manufacturing or processing equipment utilized in the plant did not qualify as Class 39 property on the basis that it was not used "primarily in the manufacturing or processing of goods for sale or lease", Major J. noted (at p.

By services, 28 November, 2015

Renaud v. The Queen, 2010 DTC 1094 [at at 2994], 2010 2010 TCC 76 -- summary under Subsection 62(3)

The taxpayer made an eligible relocation to a residence in another town. Rather than sell his old residence, he rented it, which effected a deemed disposition under s. 45(1)(a). However, Campbell J. found at para. 9 that, while "sold" means "disposed of by sale," the effect of 45(1)(a) was a disposition other than by sale. Therefore, the taxpayer was not eligible to include the s. 62(3)(f) amount in his claimed "moving expenses."

sale