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Technical Interpretation - External
24 June 2024 External T.I. 2023-1000861E5 - Clean technology property and phase out of AIIP
Relevant Income Tax Implications for Taxpayer in its December 31, 2025 taxation year A. ... (footnote 8) The Taxpayer may deduct $15,000,000 as CCA in respect of the Property (footnote 9) from its income from a business for its 2025 taxation year, which is computed as follows: Capital Cost of the Property determined under Element A of UCC $20,000,000 Add: adjustment for accelerated investment incentive $10,000,000 (i.e., 1/2 X $20M (footnote 10)) Subtotal for purposes of computing first-year CCA in 2025 $30,000,000 CCA deduction (Class 43.2 – 50% (footnote 11)) $15,000,000 B. ... If the Property was acquired in 2025, it would be included in Class 43.1, under subparagraph (d)(vi). ...
Current CRA website
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement
Table of Contents Chapter 1 – Introduction The purpose of this guidance Scope of guidance International context Chapter 2 – Definitions and glossary The meaning of certain terms Coordination of definitions with U.S. ... Example 11 – Separate account reporting Person Y holds three depository accounts with Bank Z. ... SIC codes A – Food, beverage, and tobacco B – Wood and paper C – Energy D – Chemicals, chemical products, and textiles E – Metallic minerals and metal products F – Machinery and equipment (except electrical) G – Transportation equipment H – Electrical and electronic products I – Construction and related activities J – Transportation services K – Communications M – General services to business N – Government services O – Education, health, and social services P – Accommodation, restaurants, and recreation services Q – Food retailing R – Consumer goods and services NAICS codes 11 – Agriculture, forestry, fishing, and hunting 21 – Mining, quarrying, and oil and gas extraction 22 – Utilities 23 – Construction 31-33 – Manufacturing 41 – Wholesale trade 44-45 – Retail trade 48-49 – Transportation and warehousing 51 – Information and cultural industries 53 – Real estate and rental and leasing 54 – Professional, scientific, and technical services 56 – Administrative and support, waste management, and remediation services 61 – Educational services 62 – Health care and social assistance 71 – Arts, entertainment, and recreation 72 – Accommodation and food services 81 – Other services (except public administration) 91 – Public administration However, if a financial institution has information in its files to suggest that the SIC or NAICS code is known to be incorrect or misleading, the financial institution cannot rely on the code to determine that the account holder is not a passive NFFE. 9.82 In the context of a new entity account, the account opening presents a financial institution with the opportunity to obtain the information necessary to determine the status of an account holder without having to refer to a standardized industrial code, which presumably would have been assigned on the basis of the same or similar information. ...
News of Note post
14 January 2025- 12:05am We have translated 6 more CRA interpretations Email this Content We have translated a further 6 CRA interpretations released in March of 2001. ... These are additions to our set of 3,059 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2001-03-16 28 February 2001 External T.I. 2000-0016765 F- All or substantially all Income Tax Act- Section 54.2 CRA is prepared to issue rulings on the application of the all or substantially all test in s. 54.2, which is not necessarily a 90% of FMV test Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(ii)- Clause 110.6(14)(f)(ii)(A) all or substantially all test in s. 110.6(14)(f)(ii)(A) is generally but not always a 90% of FMV test 5 March 2001 Internal T.I. 2000-0040357 F- Déductibilité- utilisation inadmissable Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) proration method applied to determine what portion of sold MFT units reduced the acquisition loan rather than equity 15 February 2001 External T.I. 1999-0008405 F- Lien de dépendance confirmed in 2004-0092871E5 F Income Tax Act- Section 84.1- Subsection 84.1(1) secured promissory note potentially could give rise to de facto control Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) holding of secured note for 80% of purchaser’s assets potentially could give rise to de facto control 2001-03-02 26 February 2001 External T.I. 2000-0017635 F- choix modifié et PBR rajusté Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(c.1) where expenses reducing ACB of transferred partnership interest were denied, automatic increase in agreed amount in statute-barred year of transfer under s. 85(1)(c.1) 22 February 2001 External T.I. 2000-0042795 F- Epargne indiciellle et JVM Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) no requirement to recognize interest on disposition of stock-index-linked term deposit 1 March 2001 External T.I. 2000-0050275 F- Remboursement de prime / enfant infirme Income Tax Act- Section 146- Subsection 146(8.1) overview of rules for transfer of taxpayer’s RRSP on death to financially dependent child ...
News of Note post
15 May 2025- 11:57pm CRA effectively rules that Part VI.1 tax could apply to an agreement to repurchase common shares for their current FMV, if their FMV declines by the closing time Email this Content A CCPC (B Ltd.) has two outstanding classes of common shares: the Class B common shares are held by three taxable Canadian corporations or partnerships (C, D, and E): and the Class A common shares are held by three inter vivos trusts. ... Summary of 2024 Ruling 2023-0970691R3 F under s. 248(1) – taxable preferred share – (a)(i). ...
News of Note post
8 June 2025- 11:12pm CRA finds that a financial institution’s investment in a non-resident partnership generally does not give rise to zero-rated supplies after the initial investment Email this Content A Canadian financial institution made a capital contribution to a “Non-Resident Partnership”) between a general partner and a limited partner, with a resulting credit to its capital account. ... Finally, the making of an additional capital contribution by all partners would not be a taxable supply made for consideration, as no consideration (i.e., partnership interest, further right or enhancement) would be received in return for doing so – so that, again, this could not generate ITCs. ... VI-IX-1, s. 141.02(1)- non-attributable input, s. 123(1) – financial service- (n), and (f). ...
Current CRA website
Income Tax Audit Manual
Income Tax Audit Manual Compliance Programs Branch (CPB) Information This chapter was last updated March 2025. ... Paragraphs 163(2)(c) through (g) of the ITA provide for penalties on the: Canada Child Benefit – Section 122.6; GST/HST credit – section 122.5; refundable medical expense supplement – subsection 122.51(2); refundable investment tax credit – subsection 127.1(1); beneficiaries of income from a qualifying environmental trust – subsection 127.41(3); Canadian film or video production tax credit – subsection 125.4(3); and film or video production services tax credit – subsection 125.5(3). ... Legislative authority – Income tax (2) ITA provision Application Guilty of an offence punishable on summary conviction by Subsection 239(2.2) Non-authorized communication or use of confidential information • a maximum fine of $5,000; or • imprisonment for a maximum of 12 months; or • both the fine and the emprisonment. ...
Current CRA website
Reporting fees for service: Online questionnaire - What we learned report
Reporting fees for service: Online questionnaire- What we learned report March 2025 Prepared by the Canada Revenue Agency Overview, purpose and results Overview and purpose Through an online questionnaire, the Canada Revenue Agency (CRA) invited Canadian businesses and organizations of all sizes to share feedback on reporting fees for service (RFS). ... Percentage Yes 67% No 33% Base all (n = 1,460) Note: Business and organization size by number of employees – micro (1-5), small (6-99), medium (100-499), large (500+). ... Figure 14 – Business and organization size (%) Text version Figure 14 displays the following information in a vertical bar graph: Business and organization size Yes No Large (500+) 75% 25% Medium (100 – 499) 72% 28% Small (6 – 99) 67% 33% Micro (1 – 5) 61% 39% Base all (n = 1,460) Figure 15 – Sectors of the economy (%)* Text version Figure 15 displays the following information in a horizontal bar graph: Sectors of the economy* Yes No Transport and warehousing 73% 27% Education services 72% 28% Retail trade 72% 28% Wholesale trade** 70% 30% Finance and insurance 70% 30% Professional, scientific and technical services 70% 30% Health care and social assistance 53% 47% Construction** 50% 50% Base all (n = 1,460) Based on the current requirements for RFS as provided on Canada.ca, how prepared is your business to comply? ...
News of Note post
., until May 31, 2025) from this prohibition in order to facilitate the OEO Dealers in paying a rebate of such amounts to their clients who held their investment in the mutual fund prior to June 1, 2022, or who transferred their mutual fund units into OEO Dealer accounts on or after June 1, 2022 (an “OEO Rebate”). The Directorate stated: [W]here an OEO Rebate is paid by an OEO Dealer to a unitholder in a trust, in the [above] circumstances … it is likely that the OEO Rebate would be considered to be in respect of the activities of the trust or in respect of an expense of the trust. ...
News of Note post
In 2025, the capital cost of the property will have been reduced (pursuant to s. 13(7.1)(e)) by the two federal tax credits claimed and (pursuant to s. 13(7)(f)) by the NS CITC “assistance” claimed, i.e., to $4,500.000. ... Summary of 21 October 2024 External T.I. 2024-1027501E5 under Reg. 1100(2)(A), s. 127(9) – government assistance and s. 13(1). ...
News of Note post
1 January 2025- 11:34pm CRA confirms that active business income includes income from property that (having regard to Ensite) is held principally for the purpose of producing active business income Email this Content The definition “income of the corporation for the year from an active business” in s. 125(7) includes, in para. ... Summary of 3 December 2024 CTF Roundtable, Q.14 under s. 129(4) – “income” or “loss”. ...