Are statements by a taxpayer of their subjective purpose and intent relevant?
Canada (Federal), Canada
The following excerpt is from Coburn Realty Ltd. v. The Queen, 2006 TCC 245 (CanLII):
Statements by a taxpayer of his or her subjective purpose and intent are not necessarily and in every case the most reliable basis upon which such a question can be determined. The actual use is frequently the best evidence of the purpose of the acquisition. In 510628 OntarioLimited v. The Queen, 2000 GTC 877, the following was said:
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