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S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 13(27) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27) Capable of producing salable product 1.34 … Example 2 Company B purchased specialized machinery for use in its manufacturing business. ... Application to leased building 1.36 … [S]ubsection 1102(5) of the Regulations requires the cost of a building or other structure to be added to Class 1 (or Class 3) in certain circumstances rather than to Class 13. … [E]ven though a taxpayer may erect a building on leased land, it will still be considered property (other than a building or part thereof) acquired by the taxpayer within the meaning of subsection 13(27) of the Act for the purpose of the available-for-use rules. … ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 13(7.5) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7.5) Access road example 1.48 … Example 4 In order to be able to establish a sports arena at a particular location, a taxpayer builds a road to the arena at a cost of $10 million. ... Exclusion for non-prescribed property 1.49 … If the other person's property is not property described in subsections 1102(14.2) or 1102(14.3) of the Regulations, or if the cost was incurred before March 7, 1996, such cost would generally be a non-deductible, non-depreciable capital outlay that qualifies as an eligible capital expenditure. … ...

For the following particular types of business, the following factors (among others) should be given consideration: development and sale of real or immovable property – the place where the property is situated; merchandise trading – the place where the sales are habitually completed, but other factors, such as the location of the stock, the place of payment or the place of manufacture, are considered relevant in particular situations; transportation or shipping – the place of completion of the contract for carriage, and the places of shipment, transit and receipt; trading in intangible property, or for civil law incorporeal property (for example, stocks and bonds) – the place where the purchase or sale decisions are normally made; money lending – the place where the loan arrangement is in substance completed; personal or movable property rentals – the place where the property available for rental is normally located; real or immovable property rentals – the place where the property is situated; and service – the place where the services are performed. 1.54 Other factors which are also relevant, but generally given less weight than the factors listed above include, but are not limited to: the place where the contract for the sale of property or the provision of services is formed or entered into; the place where payment is received; the place where assets of the business are located; and the intent of the taxpayer to do business in the particular jurisdiction. 1.55 In the case of a single business comprised of more than one of the above-mentioned activities, each activity is considered separately for purposes of determining in which country or countries the business is carried on (this situation should not be confused with the situation in which the taxpayer has separate businesses—see Interpretation Bulletin IT-206R, Separate businesses). ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Subsection 13(28) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(28) Example of two-year rolling start rule 1.33 … Example 1 Company A owns a Class 1 building that is used to earn business income. ... The long-term election under subsection 13(29) and discussed in ¶ 1.37 is not made. ...

S5-F4-C1- Income Tax Reporting Currency-- summary under Subsection 261(6.1) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(6.1) Staggered year ends / FAPI only 1.39 Note that, similar to where a functional currency taxpayer holds an interest in a partnership, it is possible for a taxpayer and its foreign affiliate to have different tax reporting currencies where they have different tax year-ends. ...

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Determination on net basis Double counting problem – cost of labour 1.28 A problem will occur in a group of associated corporations where one corporation acts as a paymaster for the others. ...

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