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S4-F15-C1 - Manufacturing and Processing -- summary under Canadian Manufacturing and Processing Profits; Manufacturing or Processing

Examples of such activities are galvanizing iron, creosoting fence posts, dyeing cloth, dehydrating foods, and homogenizing and pasteurizing dairy products. 1.3 In Tenneco Canada Inc. v The Queen, [1991] 1 CTC 323, 91 DTC 5207, the Federal Court of Appeal indicated that the two tests for determining whether a taxpayer is engaged in processing are: whether there is a change in the form, appearance, or other characteristics of the goods subject to the operation; and whether the product becomes more marketable. 1.4 The activities of breaking bulk and repackaging for subsequent resale where there is a systematic procedure to make a product more marketable are generally considered to be processing. ...

S3-F4-C1 - General Discussion of Capital Cost Allowance -- summary under Subsection 152(4)

This might occur, for example, because of a reallocation of the total purchase price of a piece of real estate between land and buildings or where an error was made by claiming CCA on a property that is not considered depreciable property. ...

S7-F1-C1 - Split-receipting and Deemed Fair Market Value -- summary under Subsection 248(35)

The shares are not listed on a designated stock exchange and are considered capital property to the individual. ...

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph (d)

A security that is approved for listing or that has a conditional approval for listing is not at that time considered to be listed on a designated stock exchange. ...

S3-F10-C2 - Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subsection 207.06(2)

Each waiver request will be considered on its own merits. Example 4 The following example illustrates a situation in which the CRA may give favourable consideration to a request that the 100% advantage tax be waived. ...

S4-F2-C2 - Business Use of Home Expenses -- summary under Paragraph 18(12)(b)

Other allocation methods may be considered reasonable depending on the particular circumstances.... 2.20 Where a work space that is an individual’s principal place of business is also used for personal purposes, expenses should be apportioned between business and personal use. ...

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime -- summary under Income-Producing Purpose

In most cases, such losses are more properly considered withdrawals of capital or are sustained outside the normal income-earning activities of the business. ...

S5-F2-C1 - Foreign Tax Credit -- summary under Subsection 126(1)

S5-F2-C1- Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) 1.39 The appropriate share of the foreign taxes paid by a partnership of which the taxpayer is a member is considered to be tax paid by the taxpayer. ...

S3-F4-C1 - General Discussion of Capital Cost Allowance -- summary under Improvements v. Repairs or Running Expense

Enduring benefit test 1.4 An expenditure will normally be considered capital in nature if it brings into existence an asset or advantage that has an enduring benefit. ...

S4-F14-C1 - Artists and Writers -- summary under Paragraph 8(1)(p)

When a musical instrument’s use changes, either partially or entirely, the change-in-use rules in paragraphs 13(7)(a), (b), and (c) will apply. 1.54 When there is a change in use, a musician may be considered to have disposed of and reacquired all or part of the instrument at its fair market value. ...

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