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The court held the BDC mortgage claims were limitation-barred, finding rent payments serviced the debt until February 2023 but Jenor’s later financial statements did not preserve the claim.
Subparagraph 181(3)(b)(ii) compels use of the amounts and characterizations reflected in the balance sheet accepted by the Superintendent for capital tax purposes; where unamortized realized gains are not reflected as reserves or surpluses on that accepted balance sheet, the Minister cannot include or recharacterize them as such for capital tax.
Source excerpt
The Supreme Court of Canada held that foreign exchange profit on U.S.-dollar notes had to be measured using the appellant’s accrual method, reducing the 1952 assessment.
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