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Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Subsection 1102(4)
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Regarding whether the costs of such work should be added to the cost of the taxpayer’s Class 13 leasehold interest pursuant to Reg. 1102(4) before regard was had to Reg. 1102(5), CRA stated: [A]n amount expended is for the making of improvements or alterations to a leased property within the meaning of subsection 1102(4) where such expended amount relates to property that is incorporated into the leased property and becomes the property of the lessor. … Generally, the owner of a building owns everything that is joined to the building. ...
Article Summary
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35 -- summary under Clause 149(1)(o.2)(ii)(A)
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) Issues where co-investing in real estate (pp. 29:18-19) [A] pension plan may want to co-invest…[and] might establish a real estate corporation…. … If the real estate corporation performs any activities in relation to the real estate property, a concern may arise as to whether the real estate corporation has satisfied the requirement of subclause 149(1)(o.2)(ii)(A)(I), given that it would be performing activities on a real estate property part of which is not owned by the corporation, by another real estate corporation, or by a registered pension plan. … [Subsequently to … 9401608, CRA] stated that it had re-examined its position and was now of the view that a co-ownership situation would not jeopardize a real estate corporation’s tax status. Further, the CRA provided that the activities carried on by the real estate corporation in relation to the co-owned property should be proportionate to the interests held by “qualified” entities under subclause 149(1)(o.2)(ii)(A)(I) (that is, by the real estate corporation, by another real estate corporation, or by a registered pension plan) …. … Pension plans looking to co-invest in real estate property may want to avoid these issues by using a structure…. ...
Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Ownership
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Before quoting from Mount Robson in this regard, the Directorate indicated that: Generally, the owner of a building owns everything that is joined to the building. ...
News of Note post
But the purchase price was a once-and-for-all payment for the acquisition of an asset of enduring advantage – the 18 GMEs – which once acquired formed part of the profit-earning structure of the Trustee's business. ... Summaries of Commissioner of Taxation v Sharpcan Pty Ltd [2019] HCA 36 (High Court of Australia) under s. 18(1)(b) – Capital Expenditure v. Expense – Contract Purchases and Concessions and Licences, and s. 13(34)(b). ...
Current CRA website
Businesses – Tax information newsletter, Edition 2023-02 – June 1, 2023
Businesses – Tax information newsletter, Edition 2023-02 – June 1, 2023 June 1, 2023 Here are answers to more of your top business tax information questions Last summer, we issued a tax tip with answers to five of the top business tax information questions. ... Find out if you qualify for Scientific Research & Experimental Development tax incentives Does your business conduct research and development (R&D) work in Canada? If so, you may qualify for our Scientific Research & Experimental Development (SR&ED) tax incentives. ...
Current CRA website
Businesses – Tax information newsletter, Edition 2024-02 – May 2nd, 2024
Businesses – Tax information newsletter, Edition 2024-02 – May 2nd, 2024 New web page on the underground economy All Canadians are impacted when someone participates in underground economy activities. ... The Canada Revenue Agency can help you understand your tax obligations- Canada.ca Celebrating Canadian Innovation Week: May 13 – 17, 2024 The Scientific Research and Experimental Development (SR&ED) Tax Incentive Program is proud to support innovation across all industry sectors in Canada. ... Whether you have benefited from this program for years, or you are seeking SR&ED support for the first time, our goal remains the same – to help Canadian businesses grow through innovation! ...
Current CRA website
Businesses – Tax information newsletter, Edition: 2024-05 – October 23, 2024
Businesses – Tax information newsletter, Edition: 2024-05 – October 23, 2024 It's Small Business Week 2024 – explore the CRA's tools to support Canada's entrepreneurs This Small Business Week, the Canada Revenue Agency (CRA) is celebrating the dedication and impact of small business owners— the heart of our communities. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Regulation 805
A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ... A carries on a business through a PE in Canada and the oil & gas royalties are attributable to the PE, Part XIII… of the Act does not apply, and the company is not required to withhold tax…. ... The company is required to… use the exemption code "S" …. Where neither paragraph 805(a) nor (b)… apply, the annual royalties paid to Mr. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under F
23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F FMV addition and subtraction where drilling rights are granted for royalty Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ... However, the proceeds of disposition (i.e., $100,000 + $300,000) of the CRP (i.e. the drilling etc. rights given to the Canadian company) were subtracted from his CCOGPE pool under variable F. ...
Technical Interpretation - External summary
2 August 2013 External T.I. 2013-0475261E5 - Eligible Dividend - Late Filing 89(14.1) & 184(3) -- summary under Subsection 89(14.1)
2 August 2013 External T.I. 2013-0475261E5- Eligible Dividend- Late Filing 89(14.1) & 184(3)-- summary under Subsection 89(14.1) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14.1) A Canadian-controlled private corporation makes a s. 184(3) election to deem the excess portion of a capital dividend to be a separate taxable dividend. ... CRA indicated that it would accept a late designation request made within three years, to the extent of a GRIP balance to support an eligible dividend designation, provided the following conditions are met: * The taxpayers took reasonable steps and care to comply with the requirements in respect of subsection 83(2) and the computation of the capital dividend account at the time that the capital dividend election was originally made; * The late designation request under subsection 89(14.1) was not specifically intended by the taxpayers at the time that the subsection 83(2) election was made nor does the late designation request form part of a series of requests made on a regular basis; and, * The late designation request does not involve aggressive tax planning. ...