Income Tax Severed Letters - 2024-11-20

Technical Interpretation - External

21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA

Unedited CRA Tags
127.45, 127(5), 127(9), 20(1)(a), Class 43.1, Class 43.2, Reg. 1104(4), Reg. 1100(2) and Nova Scotia Income Tax Act, RSNS 1989, c. 217 and the Capital Investment Tax Credit Regulations made under Section 49A of the Income Tax Act, R.S.N.S.
Summary Under
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) - Element A
example of AIIP computation for solar panels
Summary Under
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance
NS CITC was reasonably expected to be received at year end even though required government certificate not yet applied for
Summary Under
Tax Topics - Income Tax Act - Section 127.45 - Subsection 127.45(5) - Paragraph 127.45(5)(b.1) - Subparagraph 127.45(5)(b.1(i))
combined effect of NS CITC and clean tech ITC
Summary Under
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1)
illustration showing recapture being realized with no disposition
  • Principal Issues: A multi-year example to illustrate the stacking of various investment tax credits (i.e., Nova Scotia Capital Investment Tax Credit, Atlantic Investment Tax Credit and the Clean Technology Investment Tax Credit) available to a hypothetical taxpayer's capital investment in a clean technology property. This example also illustrates the CCA calculations for the property during the phase-out period of the accelerated investment incentive property (i.e., full-expensing) incentive.

11 July 2024 External T.I. 2024-1008891E5 - XXXXXXXXXX One-time relief payment

Unedited CRA Tags
56(1)(u), ITR 233(1), ITR 233(2)

Principal Issues: What is the tax treatment of one-time rebate to individuals and families under the XXXXXXXXXX one-time rebate program and how to report it?

Position: Likely included in the recipients income under paragraph 56(1)(u) with an offsetting deduction from taxable income, pursuant to paragraph 110(1)(f). Likely not required to report on T5007 pursuant to 233(2)(f) or (g) of the Income Tax Regulations.

Reasons: Assistance appears to be a social assistance made on the basis of a means, needs or income test.

10 July 2024 External T.I. 2024-1010461E5 - Payments under kinship agreements et al

Unedited CRA Tags
56(1)(u); 81(1)(h); 81(1)(h.1); 110(1)(f)

Principal Issues: What will be the tax treatment of payments received by caregivers under kinship care agreements and customary care agreements with Child and Youth Services, XXXXXXXXXX Families?

Position: The payments are unlikely to be considered income from a source.

Reasons: We are advised that the payments in question are not based on a means, needs or income test of either the caregiver or the child under their care.