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Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide 2021 – Chapter 6 – Eligible capital expenditures
Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide 2021 – Chapter 6 – 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. ... For more information on changes to the ECP system, go to Explanatory Notes – Eligible Capital Property. ...
SCC (summary)
Quebec (Agence du revenu) v. Services Environnementaux AES inc., 2013 DTC 5174 [at at 6466], 2013 SCC 65, [2013] 3 SCR 838 -- summary under Rectification & Rescission
., 2013 DTC 5174 [at at 6466], 2013 SCC 65, [2013] 3 S.C.R. 838-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Quebec documents did not implement common intention to defer tax Riopel Facts Mr. ...
News of Note post
8 March 2024- 12:01am 3295940 Canada – Federal Court of Appeal finds no abuse in a tax plan producing the same gain as if the ultimate shareholder had directly used its high outside basis for its investment Email this Content The taxpayer (3295) was a holding company with a minority shareholding in a target company (Holdings) with a low ACB, whereas 3295’s parent (Micsau) had a high ACB for its 3295 shares. ... Thus, the “series’ overall result [was] consistent with the object, spirit and purpose of the capital gains regime as previously identified by this Court—that is, to tax real economic gains: Triad Gestco … “. ...
Technical Interpretation - External summary
19 November 2012 External T.I. 2012-0459351E5 - Shale Gas Well Drilling Classification -- summary under Scientific Research & Experimental Development
19 November 2012 External T.I. 2012-0459351E5- Shale Gas Well Drilling Classification-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development In considering the conditions under which a shale gas well would qualify for Canadian development expense credits, CRA noted that drilling the well may qualify for scientific research and experimental development credits if done for "experimental development of a new technology. ...
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 From: Canada Revenue Agency On this page... Identification Signing up for email notifications 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? ...
TCC (summary)
Allegro Wireless Canada Inc. v. The Queen, 2021 TCC 27 -- summary under Scientific Research & Experimental Development
The Queen, 2021 TCC 27-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development software development qualified as SR&ED The taxpayer provided a software platform to its clients to allow them to communicate remotely with their workers through wireless handheld devices used to access their employer’s computer system, in a great variety of applications. ... Agencies, found (at para. 194) that the taxpayer “was attempting to develop a new product (its platform) that would work seamlessly with a multitude of devices that used different operating software and ran on the various operating systems of [its] clients” and similarly (at para. 202) that the work undertaken by the taxpayer was "for the purpose of achieving technological advancements that would allow [it] to create a new and/or better product” found that the project had various challenging elements and that these challenges could not be resolved with routine engineering, so that it was instead required to experiment to come up with hypotheses of things that it could test also noted (at para. 209) the projects “were the same or similar to projects in respect of which the Appellant received grants from the National Research Council of Canada” Before allowing the appeal, he stated (at para. 208) … I have concluded that when the Appellant conducted the projects at issue, it formulated hypotheses specifically aimed at reducing the identified technological uncertainty, followed appropriate procedures on testing, including the formulation, testing, and modification of hypotheses, and maintained a detailed record of the hypotheses tested and results achieved as the work progressed. ...
TCC (summary)
Béton mobile du Québec Inc. v. The Queen, 2019 TCC 278 -- summary under Scientific Research & Experimental Development
The Queen, 2019 TCC 278-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development there can be reasonable certainty as to a successful outcome if the means of achieving it are uncertain The taxpayer (BMQ) used mobile concrete mixers to provide concrete at the site of construction or major repair projects. ...
News of Note post
The facts are somewhat analogous to those in Global Cash Access, where Global was charged for something analogous to cheque-cashing services by the casino in fee amounts ranging from 12.5% down to 2.5%, depending on the size of the individual amounts – with Sharlow JA finding that these were for exempt encashment services. One distinction might be that it would have been less consonant with the “economic realities” (to use a phrase of Richards LJ) to characterize these amount as being paid by Global for access to the casino – and another, that the amounts were high, but not outrageous, when viewed as consideration only for encashing. ... Summary of Wiltonpark Ltd & Ors v Revenue & Customs Commissioners, [2016] EWCA Civ 1294 under ETA s. 123(1) – financial service – para. ...
News of Note post
Maso – Privy Council confirms application of minority discount to minority bloc of public-company shares Email this Content Some minority shareholders of a Caymans NASDAQ-quoted company dissented when they were squeezed out in a going-private transaction for a modest (26%) premium over the trading price. ... Summary of Shanda Games Ltd v Maso Capital Investments Ltd & Ors (Cayman Islands) [2020] UKPC 2 under General Concepts – FMV – shares. ...
News of Note post
30 May 2021- 11:26pm Mussalli – Full Federal Court of Australia finds that “rent prepayments” made by new franchisees to reduce percentage rent payments on leases were capital expenditures Email this Content Two Australian trusts that were to be the franchisees for seven McDonald’s restaurants agreed, at the same time as they agreed to enter into leases of the premises for base rents plus sales-based percentage rents, to make a lump sum “prepayment of rent” so as to reduce the percentage rent payable. ... In finding that the rent prepayments were capital expenditures, so that such deduction was not permitted, Mckerracher and Stewart JJ stated: There is no principle that a payment that substitutes for future revenue outgoings or which compensates for them, or which more accurately in this case obviates or removes the need for them, must itself be revenue. … [I]f the term … of the lease was irrelevant to the method of calculation of the payment [as was the case here], then any argument that the payment was in truth … a computation of prepayment of rent is extremely difficult to mount. … The taxpayer has, in effect, purchased the right to have the better lease with the lower rent. … Neal Armstrong. Summary of Mussalli v Commissioner of Taxation [2021] FCAFC 71 under s. 18(1)(b) – Capital expenditure v. expense – Contract purchases or prepayments. ...