What is the test for the calculation of an allowance under the Income Tax Arrears for the purchase and use of property acquired through a property purchase scheme?
Canada (Federal), Canada
The following excerpt is from Landrus v. The Queen, 2008 TCC 274 (CanLII):
The amount of the allowance is based on the cost of the assets to the taxpayer and is intended to allocate the cost of the assets over its economic life. In the words of Noël, J.A. in Duncan v. R.,[19] “the clear and obvious purpose of the provisions is to provide for the recognition of money spent to acquire qualifying assets to the extent that they are consumed in the income-earning process."
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