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Scraped CRA Website
T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 3: Page 3 of the T2 return On this page... ... First year: 10% × $780,000 = $78,000 $78,000 ÷ 2 = $39,000 CCA (half-year rule) Second year: $780,000 − $39,000 = $741,000 (undepreciated capital cost) $741,000 × 10% = $74,100 CCA Third year: $741,000 − $74,100 = $666,900 (undepreciated capital cost) $666,900 × 10% = $66,690 CCA And so on for the following years. ... First year (2016): $9,000 ÷ 9= $1,000 $1,000 ÷ 2= $500 CCA (half-year rule) Second year and following (2017 to 2023): $1,000 CCA per year Last year of amortization period (2024): $1,000 × 1 1/2 = $1,500 CCA. ...
News of Note post
31 March 2019- 11:25pm Lavrinenko and Morrissey – Federal Court of Appeal finds that “near equal” means no lower than 45% Email this Content While normally the Canada child tax benefit (CCTB) and the GST/HST credits (the “Benefits”) can at most be claimed by only one parent, individuals who are a child’s “shared‑custody parent” are each entitled to ½ of the Benefits. ... Canada, 2019 FCA 51 under s. 122.6 – shared-custody parent – para. (b) and summary of Morrissey v. Canada, 2019 FCA 56 under s. 122.6 – shared-custody parent – para. (b). ...
News of Note post
Guimond JCQ found that, as this settling-out process (without oenophilic pretention, described in French as “décantation”) was part and parcel of the process for purifying the oils and was more significant than the use of the trucks in transporting the oil, the trucks qualified as processing equipment under the Quebec equivalent of ITA s. 127(9) – qualified property – (c)(i). The same concepts also are relevant for distinguishing CCA classes referencing manufacturing and processing – and, in fact, Guimond JCQ quoted the Démolition A.M. case extensively. ... ARQ, 2016 QCCQ 9461 under s. 127(9) – qualified property – (c)(i). ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return On this page... Identification Signing up for online mail when filing your T2 return Line 001 – Business number (BN) Line 002 – Corporation's name Lines 010 to 018 – Address of head office Lines 020 to 028 – Mailing address Lines 030 to 038 – Location of books and records Lines 040 and 043 – Type of corporation at the end of the tax year Lines 060, 061, 063, 065 – To which tax year does this return apply? ... Line 079 – If an election was made under section 261 Lines 080 to 082 – Is the corporation a resident of Canada? ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return On this page... Identification Signing up for online mail when filing your T2 return Line 001 – Business number (BN) Line 002 – Corporation's name Lines 010 to 018 – Address of head office Lines 020 to 028 – Mailing address Lines 030 to 038 – Location of books and records Lines 040 and 043 – Type of corporation at the end of the tax year Lines 060, 061, 063, 065 – To which tax year does this return apply? ... Line 079 – If an election was made under section 261 Lines 080 to 082 – Is the corporation a resident of Canada? ...
Decision summary
Ingenious Games LLP & Ors v Revenue and Customs, [2021] EWCA Civ 1180 -- summary under Section 96
" In making its “with a view to profit” determination, the Court noted that the following principles generally were common ground: [S]haring profits … [is] not an essential characteristic of a partnership [citing Young v. ... It follows that the complex mosaic of generally accepted accounting practice … will generally have little part to play. Fourth … the view to profit need not be the predominant subjective purpose, but it must be part of the partners' subjective purpose. ...
Decision summary
Harvest Operations Corp v. A.G. (Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327 -- summary under Rectification & Rescission
(Canada), 2015 DTC 5067 [at at 5904], 2015 ABQB 327-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission requested rectification order to fix bump did not match parties' specific plan at closing The Bump Mistake A predecessor in interest of the applicant ("Viking") entered a multi-step acquisition and restructuring transaction to acquire an arm's length corporation ("Krang"). ... Dario J dismissed the taxpayer's application, stating (at paras. 77, 81 and 82): [T]his is not a case of the parties "wrote it down wrong", but rather the parties got it wrong. … To the extent we are talking only about the increased bump room due to the Krang Debt, the evidence does not establish that the inability to benefit from this tax treatment would have terminated the acquisition, or that the common intent of the parties that drove them to the formation of the transaction was frustrated. … The intent to complete a transaction in the most tax efficient manner possible is not sufficiently specific. ...
Decision summary
BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber)) -- summary under Supply
BLP Group plc v Commissioners of Customs & Excise, [1995] EUECJ C-4/94 (ECJ (5th Chamber))-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply mere borrowing of money is not a supply BLP was a management holding company which provided services to a group of trading companies producing goods for use in the furniture and DIY industries. ... In finding that taking out a loan did not involve a VATable transaction by the borrower at all, even if it pays interest (it was the mere recipient of a service provided by the lender) the Court stated (at para. 47): The taking up of a loan and the selling of an interest in a company are not … operations of the same type for the purposes of the VAT system — nor are they, moreover, for an undertaking's operational purposes, since the income from the sale of shares is part of the undertaking's own resources, whereas the loan is part of its borrowed resources — because that system focuses on transactions and makes a clear distinction between taxable and exempt transactions. ...
Technical Interpretation - External summary
30 April 2009 External T.I. 2008-0296721E5 F - Late filed election 85(7) - Amending transactions -- summary under Rectification & Rescission
30 April 2009 External T.I. 2008-0296721E5 F- Late filed election 85(7)- Amending transactions-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission CRA will not anticipate a judicial rectification An individual transferred an immovable to his corporation for non-share consideration, and after being reassessed by CRA for the resulting gain, filed a late s. 85(7) election showing preferred share consideration and proposed to validate such late election by entering into a "deed of correction" with the corporation providing for the shares’ issuance. ... [E]ven if the "deed of correction" of the Contract …were to be entered into … CRA could not take it into account for the purposes of determining the tax consequences of the transfer of the Immovable. Consequently, CRA would not be able to accept a late election filed by the taxpayer and the Corporation under subsection 85(7) since, based on the Contract initially entered into … one of the conditions set out in subsection 85(1) (i.e., the issuance by the Corporation of share consideration) would not have been satisfied. ...
Technical Interpretation - Internal summary
25 September 2003 Internal T.I. 2003-0032837 F - Market Maker: Reserve Account for Losses -- summary under Payment & Receipt
25 September 2003 Internal T.I. 2003-0032837 F- Market Maker: Reserve Account for Losses-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer A firm (ABC), that employed market makers, maintained a separate account for each employee into which a portion of the commissions earned by the employee was retained and held in a contingency loss reserve account, which was to be used to cover any losses resulting from the employee's transactions, and with the employee having access to the account on leaving the employment – except that where the employee moved employment to another member firm of the same clearinghouse ABC could, at the request of and for the benefit of the employee, transfer the funds accumulated in its reserve account to another similar account administered by the new employer. In finding that such transfer would be subject to withholding under s. 153(1)(a) on the basis inter alia that there was constructive receipt by the employee, the Directorate stated: [T]his payment is made to the employee by ABC, even if the employee does not receive it directly. … The employee chooses to direct the payment to the new employer's reserve account for the employee’s benefit, rather than personally collecting the funds. ...