Section 124

Subsection 124(1) - Deduction from corporation tax

Administrative Policy

18 October 89 Meeting with Quebec Accountants, Q.8 (April 90 Access Letter, ΒΆ1166)

RC acknowledges that a taxable capital gain realized by a non-resident corporation from the disposition of taxable Quebec property will not be creditable if the non-resident corporation has no permanent establishment in Canada.

Subsection 124(4) - Definitions

Taxable Income Earned in the Year in a Province

See Also

Noranda Mines Ltd. v. The Queen, 85 DTC 5001, [1984] CTC 659 (FCA)

The words "taxable income earned in the year" in former s. 124(2)(b) referred to income for the year minus the deductions permitted by Division C for the taxation year, such as losses carried forward from prior years under section 111.

Administrative Policy

85 C.R. - Q.7

RC does not accept a provincial request to change the allocation of taxable income of the provinces until it is satisfied that the provincial position is correct.