Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024

Interpretation of gross revenue, and examples

2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s....

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CRA broad interpretation of Reg. 402(5) exclusion

2.23 Subsection 402(5) of the Regulations provides that for purposes of subsection 402(3), gross...

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Extension of gross revenue definition to Pt. IV of the Regs.

2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross...

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Inclusion of ancillary revenues

2.48 In allocating gross revenue from services, a corporation must determine the place where those services were...

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Revenue from operating leases allocated based on reasonable knowledge

2.52 [W]here the land is not used in connection with the corporation’s...

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Meaning of “normally”

2.63 The term normally is not defined for the purposes of subsection 402(7) of the Regulations. It is the CRA’s view...

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Meaning of “commission”

2.64 Under subsection 402(8) of the Regulations, for the purposes of subsection 402(7), a fee does not include a...

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Non-application of central paymaster rule to admin services

2.66 Generally, the central paymaster rules would not apply in a situation where the...

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Allocation under Reg. 402(6) in accordance with income-sharing percentage

2.71 Each member of a partnership is considered to have a permanent...

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