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Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures On this page… Find out what an eligible capital expenditure is Find out what an annual allowance is Find out what a cumulative eligible capital account is Transitional rules – Undepreciated capital cost balance Transitional rules – Deemed gain immediately before January 1, 2017 Transitional rules – Dispositions of former ECP Transitional rules – Non-arm's length dispositions of former ECP As of January 1, 2017, the eligible capital property (ECP) system was replaced with the new capital cost allowance (CCA) Class 14.1 with transitional rules. ... Transitional rules – Deemed gain immediately before January 1, 2017 You may be able to include an amount in your income in a tax year that straddles January 1, 2017. ... Transitional rules – Dispositions of former ECP Receipts related to expenditures incurred before January 1, 2017, cannot result in excess recapture when applied to reduce the balance of the new CCA class. ...
Commentary
Rectification & Rescission - Commentary
An attempt by the parties themselves to rectify their transactions on a nunc pro tunc basis may not be respected as having retroactive effect for tax purposes (see S & D), although the parties' self-help rectification in AES (replacing most of a promissory note with preferred shares) was effectively ratified after the fact in a Quebec context. ... However, in S & D, transactions were rectified so as to minimize adverse tax consequences to the extent consistent with the commercial intent of the parties, even though there had not been a continuing intention of the parties to avoid tax. ...
Article Summary
Joel A. Nitikman, "Rectification: Specific Intent? General Intent? What is the Test? – Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1. -- summary under Rectification & Rescission
– Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Test is one simply of true intention, not specific intent (pp. 3-4) In Juliar,…[t]he key passages from the Court of Appeal are these:… [I]t is possible,, even probable, that no one mentioned income tax throughout the nine or 10 months in issue. ... If there is no requirement for due diligence, it means that rectification is available even when there is a mistake — even a negligent mistake [f.n. 10. ... Coutts & Co, [2006] EWHC 1502 (Ch.) at paragraph 11, the Courts granted rectification even though the mistake was caused clearly by a professional advisor's negligence. ...
TCC
A & T Tire & Wheel Limited v. M.N.R., 2009 TCC 640
A & T Tire & Wheel Limited v. M.N.R., 2009 TCC 640 Docket: 2009-911(EI) BETWEEN: A & T TIRE & WHEEL LIMITED, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and JUSTIN BUNN, Intervener.____________________________________________________________________ Appeal heard on common evidence with the appeal of A & T Tire & Wheel Limited (2009‑912(CPP)) on November 26 and 27, 2009 at Toronto, Ontario Before: The Honourable N. ... Weisman" Weisman D.J. Citation: 2009 TCC 640 Date: 20091224 Dockets: 2009-911(EI) 2009-912(CPP) BETWEEN: A & T TIRE & WHEEL LIMITED, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and JUSTIN BUNN, Intervener. ... Weisman, Deputy Judge DATE OF JUDGMENT: December 24, 2009 APPEARANCES: Counsel for the Appellant: Leigh Somerville Taylor Counsel for the Respondent: Thang Trieu For the Intervener: The Intervener himself COUNSEL OF RECORD: For the Appellant: Name: Leigh Somerville Taylor Richler and Tari Toronto, Ontario For the Respondent: John H. ...
SCC
Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. Canada (Attorney General); R. v. Fink, 2002 DTC 7267, 2002 SCC 61, [2002] 3 SCR 209
Entreprises Végo Ltée, [1997] 2 S.C.R. 299. Statutes and Regulations Cited Canadian Charter of Rights and Freedoms, ss. 1 , 7 , 8 , 10 (b), 11 (b). Constitution Act, 1982, s. 52 . Criminal Code, R.S.C. 1985, c. C-46, ss. 487 , 488.1 [ad. c. 27 (1st Supp.), s. 71 ]. Income Tax Act, R.S.C. 1985, c. 1 (5th Supp .), ss. 232 , 239(1) (a), (d). ...
Current CRA website
Canada Emergency Wage Subsidy – Post-payment audits – Status Update –
Canada Emergency Wage Subsidy – Post-payment audits – Status Update – March 2023 On this page Purpose Scope Post-payment CEWS Audits – Key Findings Audit Selection Post-payment Audit Program – Phased Approach Post-payment CEWS audits – Segmentation Post-payment Audit Results Preparer-linked Files Observations related to Auditor General Report 10 – Specific COVID-19 Benefits Overview Key Findings Conclusion Purpose The purpose of this document is to provide an update on the Canada Revenue Agency’s (CRA's) Canada Emergency Wage Subsidy (CEWS) post-payment audit program, including results, findings, and observations with respect to the Office of the Auditor General’s (OAG) Report 10 – Specific COVID-19 Benefits tabled in Parliament on December 6, 2022. ... Post-payment CEWS Audits – Key Findings Results of completed post-payment audits demonstrate high levels of compliance. ... Of the $5.53 billion, $325 million (5.9 %) were denied or adjusted. There are 2,014 audits in progress, representing an additional $10.35 billion in CEWS claims. ...
22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] -- summary under Subsection 259(2)
22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]-- summary under Subsection 259(2) Summary Under Tax Topics- Excise Tax Act- Section 259- Subsection 259(2) CEWS and TWS did not count towards 40% government funding A non-profit organization (NPO) generally is entitled to GST/HST public service body rebates if the percentage of its “government funding” (defined in s. 2 the Public Service Body Rebate (GST/HST) Regulations) is at least 40%. ... CRA concluded that the CEWS was not government funding under the definition, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ CRA applied a somewhat similar analysis to find that the 10% temporary wage subsidy for employers program also did not count as government funding. ...
22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] -- summary under Government Funding
22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]-- summary under Government Funding Summary Under Tax Topics- Excise Tax Act- Regulations- Public Service Body Rebate (GST/HST) Regulations- Section 2- Government Funding CEWS received by an NPO does not qualify as government funding for GST/HST PSB rebate purposes Are the Canada emergency wage subsidy (“CEWS”) and the 10% temporary wage subsidy for employers (“TWS”) programs considered government funding for purposes of s. 2 the Public Service Body Rebate (GST/HST) Regulations? After noting that s. 2 excluded a “refund, rebate or remission of, or credit in respect of, taxes” and referenced a purpose of “financially assisting the particular person in carrying out the purposes of the particular person” and further indicating that the purpose of the two programs was to “re-hire workers previously laid off as a result of COVID-19, help prevent further job losses, and better position businesses to resume normal operations following the crisis,” CRA found that the CEWS was not government funding under s. 2, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ Regarding the TWS, it also noted that an eligible employer does not reduce its deductions from its employees’ pay and remits less to the Receiver General. ...
SCC
In re Income Tax Act (Manitoba) / Thos. Jackson & Sons, Ltd. v. The Municipal Commissioner, [1936] SCR 616
In re Income Tax Act (Manitoba) / Thos. Jackson & Sons, Ltd. v. The Municipal Commissioner, [1936] S.C.R. 616 Supreme Court of Canada In re Income Tax Act (Manitoba) / Thos. ... S. 4 (p) (enacted in 1930. c. 22) provided that “profits of a * * * joint stock company * * * accumulated prior to and undistributed at” December 31, 1929, be not liable to taxation under s. 8 (4). ... Solicitors for the appellant: Johnston, Major, Finlayson & Fraser. ...
Technical Interpretation - Internal
29 November 1991 Internal T.I. 912299 F - Ontario R & D Superallowance and the Quebec R & D Tax Credit
29 November 1991 Internal T.I. 912299 F- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes:- will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act;- will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;- will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and We confirm this understanding. Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes:- will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act;- will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;- will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and- will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...