Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

Summary Under
Tax Topics - Other Legislation/Constitution - British Columbia - Provincial Sales Tax Act - Section 1 - Tangible Personal Property
Supplies of real property v. tangible personal property (p. 10:31)

[R]eal property in British Columbia includes land, buildings and structures,...

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Tax Topics - Other Legislation/Constitution - British Columbia - Provincial Sales Tax Act - Section 1 - Taxable Services
Exemption for services to install TPP that will become real property (p. 10:31)

Taxable services include any service provided to install,...

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Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(l.1)
Proxy income inclusion does not boost unit ACB (p. 10:13)

[I]f a corporate partner exceeds the permitted 1.5:1 ratio, interest expense on...

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Summary Under
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Investment
Application of "replicate" test to public company investors (pp. 10:23-4)

[T]he "replicate test" within the definition of "investment" in...

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Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) - Paragraph 13(27)(b)
Use of rolling-start rule in s. 13(27)(b) to accelerate CCA (p. 10:20)

[G]iven the long duration of major construction projects, the rolling-start...

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Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29)
Long-term project rule may permit faster CCA write-offs for long-term projects (p. 10:20)

When the creation of an asset in a major construction...

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Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(c)
Simplified overview of rule (p. 10:13)

A back-to-back loan exists when a Canadian resident has an outstanding interest-bearing debt obligation...

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Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(d)
Simplified overview of rule (p. 10:13)

[A] safe harbour exists when the intermediary debt represents less than 25 percent of the Canadian debt,...

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Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1)
Treatment of fees as s. 20(1)(e.1) deductions (pp. 10:22-3)

It is unlikely that the initial professional fees related to the financing of a major...

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Summary Under
Tax Topics - Income Tax Act - Section 21 - Subsection 21(1)
Capitalization of financing costs (p. 10:22)

[S]ubsection 21(1) allow[s] a taxpayer to capitalize certain costs of financing to any related...

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Summary Under
Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter
Sale of interest in LNG project potentially a tax shelter (p. 10:25)

[A] proponent of a major construction project seeks to sell all or a portion...

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Summary Under
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(1) - Adjusted Stub Period Accrual Income
Deferral with choice of partnership year-end with partnership in start-up (p. 10:5)

Many major construction projects are not taxable for a number...

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Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14
Construction costs incurred for Class 14 licence (p. 10:18)

[The project] contract states that in exchange for granting the concession, the P3...

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