Précis: Devon Canada Corporation (“Devon”) sought to deduct payments made by predecessor corporatons to their employees in exchange for those employees surrendering various share purchase options (the “Surrender Payments”). In its notices of appeal Devon sought to rely upon section 9 of the Income Tax Act (the “Act”) and, in the alternative, paragraphs 20(1)(b)(eligible capital expenditures) and 20(1)(e) (financing expenses).
Devon Canada v. R. - FCA: Court holds CRA accepted new grounds of objectionREAD MORE »