Income tax
Income Calculation
Appeals from three decisions of Tax Court of Canada (2008 TCC 106) confirming assessments made by M.N.R. under Income Tax Act, R.S.C., 1985 (5th Supp.), c. 1—Whether Act, s. 10(1) authorized appellants to compute their income in manner inconsistent with Generally Accepted Accounting Principles (GAAP)—Relying on Act, s. 10, requiring inventory be valued at lower of cost or fair market value, appellants reporting income on basis of billed rather than earned income, contrary to GAAP applicable under s. 9—Supreme Court of Canada already holding, in Friesen v. Canada, [1995] 3 S.C.R. 103, s. 10(1) mandatory provision ruling out general application of s. 9 for valuation of business inventory—Appeals allowed.
CDSL Canada Ltd. v. Canada (A-122-08, A-123-08, A-121-08, 2008 FCA 400, Noël J.A., judgment dated December 15, 2008, 17 pp.)