goods

18 July 2002 Internal T.I. 2002-0135177 F - TRANSPORT DE MARCHANDISES -- summary under Paragraph 8(1)(g)

The Directorate indicated that the expression "goods transport" does not refer solely to the transport of goods intended for sale, and included the transport of mail, but that the transport of money or securities by armoured truck was not included.

17 May 2022 IFA Roundtable Q. 3, 2022-0926191C6 - Meaning of "goods" under 95(3)(b) -- summary under Paragraph 95(3)(b)

A wholly-owned foreign affiliate (“FA”) of a corporation resident in Canada (“Canco”) provides marketing services for FMV fees to Canco respecting the sale of Canadian residential condominiums by Canco in the course of its Canadian business. Does real estate inventory, such as the Canco condos, held for sale in the regular course of business qualify as “goods” for purposes of s. 95(3)(b) so that, in this case, s. 95(3)(b) would oust the application of s. 95(2)(b) to the services income of FA?

By services, 28 November, 2015

Canadian Wirevision Ltd. v. The Queen, 79 DTC 5101, [1979] CTC 122 (FCA) -- summary under Canadian Manufacturing and Processing Profits

A cable television company argued unsuccessfully that it was processing goods for resale when it processed T.V. signals for transmission to its subscribers. Although electricity can be bought and sold as a commodity or "good", in this situation the television signals would not be referred to in common parlance as goods. In addition, the contracts with its subscribers indicated that it was supplying services rather than goods to them.

goods

goods

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