Words and Phrases - "expense incurred"
6 November 2003 External T.I. 2003-0039525 F - Canadian Renewable & Conservation Expenses
CCA is not an outlay or expense, and cannot qualify as CRCE
A corporation implementing a Canadian renewable and conservation expenses (CRCE) project that uses landfill sites, and injects them with bacteria to produce recoverable gas, puts a structure (pipes) into the ground to recover the gas and also uses other equipment such as computers. Could CCA deducted by the taxpayer qualify as CRCE? CCRA responded:
CCA claimed by a taxpayer under paragraph 20(1)(a) of the Act would not be an ""expense incurred by a taxpayer". In fact, CCA is a deduction that paragraph 20(1)(a) … and the Regulations allow to offset the capital cost of acquiring a property. Absent these provisions, such capital cost would otherwise be non-deductible under the terms of paragraph 18(1)(b) … . [See] McKee ... .
Words and Phrases
expense incurred| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) | CCA is not an expense incurred | 106 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(viii) | computers used in operating landfill biogas site might be Class 10 property, and applications software would be Class 43.1 or Class 12 property/ below-surface pipes would not qualify | 302 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 12 - Paragraph 12(o) | applications software used by computers for operation of biogas landfill site would be Class 43.1 or Class 12 property | 180 |