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Technical Interpretation - Internal
21 January 2015 Internal T.I. 2014-0540631I7 - S.261 and loss carryback request
All subsequent year non-capital losses that have previously been deducted under paragraph 111(1)(a) should be considered. ... Where this occurs under either instalment method, that particular method will not be considered. ... Should previously applied non-capital losses from subsequent years be considered in recalculating CAD Taxes Payable resulting from a subsequent deduction for an additional non-capital loss? ...
Technical Interpretation - External
28 June 1990 External T.I. 9008555 F - Election to Transfer Capital Property from One Class to Another
In view of the above, it is our opinion that where it can beestablished that more than 5O% of the use of a farm residence, owned by a farm partnership, is used as accommodation for persons (or their dependants) who are actively employed in the farming business, such residence would be considered to be property used in the business of farming for purposes of the definition of "interest in a family farm partnership" in subsection 110.6(1). ...
Miscellaneous severed letter
26 May 1988 Income Tax Severed Letter RCT 7-2892 F
Our Comments XXX on subsection 247(2) which has considered the meaning of the reference to "... one of the main reasons... ...
Technical Interpretation - Internal
22 August 1996 Internal T.I. 962706B - FINANCIAL ASSISTANCE - SAGUENAY FLOOD VICTIMS
Tax consequences (a) The amount of financial assistance relating to the destruction or total loss of such buildings will be considered the proceeds of disposition for the land and the building. ... Financial Assistance for damage (not considered a total loss) incurred by the owner of a residence. certain rental buildings and business properties Assistance- The owner could receive 100% of the value of the damage to the building, up to $100,000, plus 75% of the amount exceeding $100,000, but not more than 100% of the standard municipal assessment of the building alone, if the owner has suffered damage to the property mentioned in the preceding section, but not a total loss.- For essential business property or property required for the continuation of business operations, the Quebec government order 973-96 states that the damage to the land (except for cultivated agricultural land) and its landscaping, or to a woodlot, sugarbush or tree plantation are not eligible for financial assistance. ...
Technical Interpretation - Internal
11 June 1998 Internal T.I. 9814567 - YEAR 2000 EXPENDITURES QUESTIONS AND ANSWERS
Are fax machines, printers, security systems or other machinery considered? ...
Conference
15 June 2022 STEP Roundtable Q. 18, 2022-0924791C6 - McNeeley et al v. The Queen
The issues considered in the case The issues which the Tax Court had to consider included the following: 1. ...
Archived CRA website
ARCHIVED - Meaning of "Construction"
The work described in (a) above is considered to be a component part of the building, whereas (b) refers to work related to the machinery or equipment that is used for manufacturing or processing purposes and is not considered to be a component part of the structure. ... However, if the circumstances have subsequently changed and the activity can be considered, over a reasonable period, to be an integral part of the construction undertaking, the separate activity may be considered to have ceased at the beginning of that reasonable period, and the activity may be considered to be construction. ... The concrete is not considered finished goods until the removal from the mixer, but the actual placing of concrete on-site is, in general, considered to be construction. ¶ 8. ...
Scraped CRA Website
ARCHIVED - Meaning of "Construction"
The work described in (a) above is considered to be a component part of the building, whereas (b) refers to work related to the machinery or equipment that is used for manufacturing or processing purposes and is not considered to be a component part of the structure. ... However, if the circumstances have subsequently changed and the activity can be considered, over a reasonable period, to be an integral part of the construction undertaking, the separate activity may be considered to have ceased at the beginning of that reasonable period, and the activity may be considered to be construction. ... The concrete is not considered finished goods until the removal from the mixer, but the actual placing of concrete on-site is, in general, considered to be construction. ¶ 8. ...
Archived CRA website
ARCHIVED - Meaning of "Construction"
The work described in (a) above is considered to be a component part of the building, whereas (b) refers to work related to the machinery or equipment that is used for manufacturing or processing purposes and is not considered to be a component part of the structure. ... However, if the circumstances have subsequently changed and the activity can be considered, over a reasonable period, to be an integral part of the construction undertaking, the separate activity may be considered to have ceased at the beginning of that reasonable period, and the activity may be considered to be construction. ... The concrete is not considered finished goods until the removal from the mixer, but the actual placing of concrete on-site is, in general, considered to be construction. ¶ 8. ...
Old website (cra-arc.gc.ca)
The Status of Bunker C Fuel Oil for the Purpose of the Definition of 'Diesel Fuel' in Subsection 2(1) of the Excise Tax Act (ETA)
A person who blends distillate fuel oil (e.g., commercial diesel fuel) with bunker C fuel oil to produce a distinct grade of fuel oil having a specific viscosity will be considered a manufacturer or producer where the blended fuel oil is considered to be "diesel fuel" for excise tax purposes. ... Since the fuel oil is actually used in an internal combustion engine of the compression-ignition type it is considered to be "diesel fuel" and subject to excise tax. ... The blending of distillate fuel oil with bunker C fuel oil to produce a distinct grade of fuel oil having a specific viscosity is considered to be manufacturing or producing where the blended fuel oil is considered to be "diesel fuel" for excise tax purposes. ...