Cases
Praxair Canada Inc. v. The Queen, 93 DTC 5100 (FCTD)
The taxpayer received Class C preference shares of a company in satisfaction of subordinated debentures and unpaid interest owing to it by the company. Walsh J. accepted the taxpayer's argument that the "amount" received by the taxpayer was less than the par value of the preference shares and stated that "it is therefore the value in terms of money of the right or thing which must be included for tax purposes under 12(1)(c)" (pp. 5105 - 5106).
The Queen v. Dresden Farm Equipment Ltd., 89 DTC 5019 (FCA)
The taxpayer had no "cost amount" for inventory held by it on consignment because it had incurred no cost for the purchase of the goods. Therefore, it had no property whose value could be determined under the lower of cost and market rule.
Administrative Policy
31 May 1999 T.I. 5-990674 -
Because the delisting or suspension of trading of a share does not cause the taxpayer to cease to own its share, or cause a disposition of its share, such event will not result in a reduction in the cost amount of its share.
1996 Ruling 960994
The cost amount for purposes of s. 206(2) of investments in exchange-traded futures contracts and forward currency contracts will be equal to the brokerage fees and other costs incidental to entering into the contract, and will not include an amount in respect to the contract price or amounts paid as initial or variation margin.
92 CPTJ - Q.8
The cost amount of a Canadian resource property is nil irrespective of the existence of undeducted resource pools.
30 July 1992 T.I. 921871 (April 1993 Access Letter, p. 153, ¶C248-131)
Accounts receivable normally would be considered to be capital property, with the result that their cost amount normally would be determined under paragraph (b). Otherwise, their cost amount would be determined under paragraph (f).
D'Aurelio, "International Issues: A Revenue Canada Perspective", 1990 Conference Report, C. 44, under "Cost Amount of Debt Denominated in Foreign Currency and the Meaning of the Words 'Amount Outstanding at That Time'"
11 December 1989 T.I. (May 1990 Access Letter, ¶1222)
The "amount" of a receivable or other debt is interpreted to mean the face amount of the debt or right to receive an amount and not necessarily its fair market value.
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", draft version of paper for CTF 2043 Conference Report.
Whether money has cost amount (pp. 10-11)
Section 143.3 applies to limit the cost of "property" acquired by the taxpayer, and does not include an express carve-out for money. …
It may be that the Department of Finance determined that a clarifying rule was unnecessary since the general scheme of the Act suggests that money does not have a cost amount and that a taxpayer does not realize a gain or loss on the disposition of money, other than in the context of foreign currency fluctuations. [fn 62: That does not mean, however, that money could not have a "cost", such that a clarifying rule would have been welcome.] By way of example:
• paragraph 88(l)(d) refers to "the cost amount to the subsidiary of the property immediately before the winding-up, plus the amount of any money of the subsidiary on hand immediately before the winding-up";…[also citing, ss. 88(1)(d), 87(9), 98(3)(a)(ii), 89(1) – GRIP. 108(1) – cost amount, 132(4)].