processing

Summary Under
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) - Subparagraph (c)(i)
processing of fuel could constitute “processing” goods

Whether equipment acquired by the taxpayer constituted qualified property for the purposes of claiming the Atlantic investment tax credit (AITC)...

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Words and Phrases
processing
Summary Under
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits
operation of breaking bulk packages into smaller lots for repackaging and sale was not “processing”

An operation of the taxpayer consists of taking products, received in bulk in boxes, and dividing them up by category according to specific...

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Words and Phrases
processing

Coop de travailleurs en serres Belle-de-Jour v. Agence du revenu du Québec, 2019 QCCQ 6609 -- summary under Class 29

Full Title
Coop de travailleurs en serres Belle-de-Jour v. Agence du revenu du Québec, 2019 QCCQ 6609
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29
greenhouse heating equipment was used in non-farming manufacturing of floral arrangements

The taxpayer used approximately 20% of the area within greenhouses to grow cucumbers or other vegetables, or flowers, from seed for sale as...

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Words and Phrases
processing
manufacturing

Canada v. Repsol Energy Canada Ltd., 2017 FCA 193 -- summary under Paragraph 1(n)

Full Title
Canada v. Repsol Energy Canada Ltd., 2017 FCA 193
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 - Paragraph 1(n)
“integration principle” applied to find that a jetty was a “processing” asset

The taxpayers were the partners of a limited partnership which constructed a terminal and jetty in St. John to which liquid natural gas would be...

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Words and Phrases
processing
distribution
integration principle

Repsol Canada Ltd. v. The Queen, 2015 TCC 21, aff'd 2017 FCA 193 -- summary under Class 1

Full Title
Repsol Canada Ltd. v. The Queen, 2015 TCC 21, aff'd 2017 FCA 193
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1
LNG regasification jetty and terminal were one asset for processing before distribution

The taxpayers were related companies, and the general partner and a 75% limited partner of a partnership which constructed a terminal and jetty in...

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Words and Phrases
distribution
processing

Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA) -- summary under Canadian Manufacturing and Processing Profits

Full Title
Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits
only operations significantly changing goods' character are "manufacturing" or "processing"

In finding that a corporation which assembled and installed exhaust systems in automobiles was not engaged in manufacturing ("producing for sale...

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Words and Phrases
manufacturing
processing
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