Subsection 123.4(1)
Full Rate Taxable Income
Administrative Policy
2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.1, 2016-0674221C6 F - General deduction from tax - 123.4
A Québec Canadian-controlled private corporation that did not benefit from the applicable Québec small business deduction could benefit from not...
Paragraph (b)
Administrative Policy
2 June 2022 External T.I. 2019-0828381E5 - Tax Rate on Rental Income in Excess of SBD
Opco, which is a CCPC that has exceeded the $15 million “taxable capital employed in Canada” threshold such that the small business deduction...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 129 - Subsection 129(4) - Aggregate Investment Income | rental income of CCPC from non-specified investment business rental property is not AII | 132 |
7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 4, 2021-0895991C6 F - Déduction pour don de bienfaisance corporatif
Where a corporation realizes both business income and a capital gain in the year in which it makes a gift, the mechanism for calculating the...
Subparagraph (b)(iii)
See Also
DAC Investment Holdings Inc. v. The King, 2024 TCC 63
With a view to its imminent disposition of the shares of a subsidiary, the taxpayer continued to the British Virgin Islands, with the result that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | no abuse in avoiding CCPC status by continuing to BVI | 406 |
| Tax Topics - Income Tax Act - Section 123.3 | object of s. 123.3 was to impose refundable tax only on CCPCs | 214 |
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(5.1) | rationale of s. 250(5.1) is to equate the place of continuance of a corporation with its place of incorporation | 205 |