![]() ![]() In Alcan, this category encompassed the fees that were incurred to help the board of directors make management decisions about the company’s income-earning process. Oversight expenses: These expenses do not have an enduring impact-they are current expenses incurred to assist management in the decision-making process and are deductible in the year incurred.The FCA agreed with the TCC’s approach of summarizing the expenses into the following two categories: Hogan designating certain fees for services as “oversight expenses” and others as “execution costs." 1 Following a review of the TCC’s findings and related jurisprudence, the Federal Court of Appeal (FCA) upheld the TCC’s decision. The Queen, 2016 TCC 172 ( Alcan), the Tax Court of Canada (TCC) partially rejected the CRA’s decision, with presiding Justice Robert J. However, the Canada Revenue Agency disallowed all of these expenses on the basis that they were capital in nature. ![]() In particular, Alcan paid investment banks to advise on a potential merger transaction-specifically, on whether to proceed and, if so, how to structure the transaction.Īlcan deducted all of the consulting fees paid to the investment banks on the basis that the expenses were current in nature and incurred for the purposes of earning income from a business or property. (Alcan), paid significant transaction costs to various advisors.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |