(a)-(b)

Paragraph 20(1)(a) - Capital cost of property

Revising Claims

Cases

Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175

The taxpayer, which first made a request at trial that it be permitted CCA claims for Ontario purposes in computing its income for 1974 in the...

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See Also

St. Benedict Catholic Secondary School Trust v. The Queen, 2020 TCC 109

The taxpayer, over the course of its 1997 to 2003 taxation years, claimed capital cost allowance and generated non-capital losses. When CRA...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - E Variable E could not be subsequently adjusted by reversing CCA claims 375

Administrative Policy

13 March 2012 External T.I. 2012-0432111E5 - Revised joint venture policy

After adverting to the previous withdrawal of its position that joint venture income could be computed as if the joint venture had a separate...

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7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite

CRA reassessed Opco to deny an investment tax credit claimed for Year 1, which was permitted based on a misrepresentation attributable to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) tax from s. 152(4)(a)(i) reassessment of statute-barred year could not be offset through increased CCA claims for that year 321

19 October 2010 External T.I. 2010-0369671E5 F - Révision d'une déduction pour amortissement

Can a revision be made to capital cost allowance claimed in a previous taxation year regarding partnership property? CRA responded:

In general, a...

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13 May 2005 Internal T.I. 2005-0127041I7 F - Revisions of CCA and non-capital loss claims

Opco initially filed its return for its 2000 taxation year on the basis on deducting a non-capital loss (“NCL”) carried forward from its 1997...

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28 July 1995 External T.I. 9519555 - IT-315

Respecting the acquisition of shares of a corporation that is financed by interest-bearing debt issued by the purchaser to the vending...

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88 C.R. - Q.44

Where RC reviews an acquisition of a building which occurred 10 years previously and determines that its capital cost was $50,000, rather than the...

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IC 84-1 "Revision of Capital Cost Allowance Claims and Other Permissive Deductions"

10. Where a taxpayer requests a revision of capital cost allowance claimed in a taxation year for which a notification that no tax is payable had...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 160

Paragraph 20(1)(bb)

Articles

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016.

Narrow CRA interpretation of principal business test (p. 236)

Since the principal business test in paragraph 20(1)(bb) requires only that the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(3) 374
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(4) - Paragraph 251.1(4)(d) 437
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(g) - Subparagraph 251.1(1)(g)(ii) 115
Tax Topics - Income Tax Act - Section 164 - Subsection 164(6) 141
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3.2) 331
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(1) 144
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(3) - Paragraph 251.2(3)(b) 112
Tax Topics - Income Tax Act - Section 252.2 - Subsection 252.2(2) 115
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(i) 176
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) - Paragraph 70(6)(d.1) 161
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) 1201
Tax Topics - Treaties - Income Tax Conventions - Article 29B 239
Tax Topics - Income Tax Act - Section 248 - (2)-(41) 157
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) 199
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.2) 59
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.3) 38
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(6) 174
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) 164
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) 163
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) 91
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(18) 49
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.01) 66
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(19) 311
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) 125
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) 379

Paragraph 20(1)(b) - Cumulative eligible capital amount

Administrative Policy

16 November 89 T.I. (April 90 Access Letter, ¶1169)

The deduction in s. 20(1)(b) cannot be applied to income from property.