Section 125

Subsection 125(1) - Small business deduction

Cases

Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

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Words and Phrases
control

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13 June 2017 STEP Roundtable Q. 8, 2017-0693381C6 - Single-member disregarded U.S. LLC

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Tax Topics - Treaties - Articles of Treaties - Article 26 no relief under Art. 26(1) of US Treaty re LLC with U.S.-source income and single Canadian-resident member 141
Tax Topics - Treaties - Articles of Treaties - Article 29 single member LLC with dual resident member could elect to be C-Corp and S-Corp, and then consider applying for relief under Art. 29(5) 150

20 June 2016 External T.I. 2016-0648481E5 F - Small business deduction and GRIP

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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Adjusted Taxable Income CCPCs can choose to forego the small business deduction so as to maximize their GRIP 110

92 C.R. - Q.50

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85 C.R. - Q.56

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IT-73R6 "The Small Business Deduction" 26 March 2002

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Articles

Perry Truster, "Expanding into the U.S", Tax for The Owner-Manager, Vol. 2, No. 1, January 2002

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Durnford, "The Distinction Between Income from Business and Income from Property, and the Concept of Carrying on Business", 1991 Canadian Tax Journal, p. 1131.

Paragraph 125(1)(a)

Subparagraph 125(1)(a)(i)

Clause 125(1)(a)(i)(B)

Administrative Policy

20 April 2017 External T.I. 2016-0679721E5 - The small business deduction

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Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Corporate Income sales of product to private corporation in which brother or father of the vendor shareholder has a controlling interest 304

Subsection 125(3) - Associated corporations

See Also

Deneschuk Building Supplies Ltd. v. The Queen, 96 DTC 1467 (TCC)

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Subsection 125(4) - Failure to file agreement

Articles

Louis, "Family Trusts - Panacea or Ticking Time Bomb?", Canadian Estate Planning and Administration Reporter, August 2, 1994, p. 1

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Subsection 125(5.1) - Business limit reduction

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14 September 2017 External T.I. 2017-0685121E5 F - Associated corporations

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(f) - Subparagraph 256(1.2)(f)(ii) Childco associated with Parent-controlled corp whose non-voting equity is held by family trust 83
Tax Topics - Income Tax Act - Section 256 - Subsection 256(2) - Paragraph 256(2)(b) - Subparagraph 256(2)(b)(ii) election under s. 256(2)(b)(ii) busts s. 256(2)(a) transitivity but not association with 3rd corporation 294

21 January 2013 External T.I. 2012-046881E5 -

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Subparagraph 125(6)(b)(ii) [repealed]

Cases

The Queen v. B & J Music Ltd., 83 DTC 5074, [1983] CTC 50 (FCA)

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Subsection 125(7) - Definitions

Active Business Carried On by a Corporation

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16 November 2004 External T.I. 2004-008194 -

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Business Tax

Canadian-Controlled Private Corporation

Cases

Kaleidescape Inc. v. MNR, 2014 ONSC 4983

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Tax Topics - General Concepts - Rectification & Rescission clarification that directions to a trustee shareholder were to be made by the mooted CCPC's board rather than a non-resident executive 395

Canada v. Bioartificial Gel Technologies (Bagtech) Inc., 2013 DTC 5155 [at 6361], 2013 FCA 164

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Canada v. Perfect Fry Company Ltd., 2008 DTC 6472, 2008 FCA 218

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Sedona Networks Corporation v. Canada, 2007 DTC 5359, 2007 FCA 169

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Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

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Parthenon Investments Ltd. v. Canada (National Revenue), 97 DTC 5343 (FCA)

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International Mercantile Factors Ltd. v. The Queen, 90 DTC 6390 (FCTD), aff'd 94 DTC 6365 (FCA)

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Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

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See Also

Durocher v. The Queen, 2016 DTC 1013 [at 2584], 2015 TCC 297, aff'd 2016 CFA 299

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Tax Topics - General Concepts - Illegality potential illegality of an option to acquire control of a private corporation did not nullify the option, so that the corporation was not a CCPC 165
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share potential illegality of 3rd-party option to acquire control of a subsidiary corporation did not nullify the option, so that the subsidiary was not a CCPC 195

Bioartificial gel technologies (Bagtech) inc. v. The Queen, 2013 DTC 1048 [at 228], 2012 TCC 120, aff'd 2013 FCA 164 supra.

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Perfect Fry Company Ltd. v. The Queen, 2007 DTC 588, 2007 TCC 133, aff'd supra 2008 DTC 6472, 2008 FCA 218

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Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505

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McClintock v. The Queen, 2003 DTC 576, 2003 TCC 259

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24 March 2017 External T.I. 2016-0662381E5 F - Control - unanimous shareholders agreement

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Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) highly contingent secondary call right of a non-resident on shares of minority residents undercuts for CCPC purposes their USA right to appoint half the board 485
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(ii) no application if non-resident under USA cannot control board decision to redeem residents’ shares – applies if automatic redemption requirement 393

10 June 2016 STEP Roundtable Q. 7, 2016-0634911C6 - Deemed Resident Trust and CCPC Status

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Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) CCPC status not included in s. 94(3)(a) 40

6 May 2014 CALU Roundtable, 2014-0523301C6 - Control - unanimous shareholders agreement

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91 C.R. - Q.9

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) 21

3 October 89 T.I. (March 1990 Access Letter, ¶1153)

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) 73

Income of the Corporation for the Year From an Active Business

Cases

Borstad Welding Supplies (1972) Limited v. The Queen, 94 DTC 6205 (FCTD)

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Freeway Properties Inc. v The Queen, 85 DTC 5183, [1985] CTC 222 (FCTD)

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Sedgewick Co-operative Association Ltd. v. The Queen, 83 DTC 5455, [1984] CTC 14 (FCTD)

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The Queen v. Rockmore Investments Ltd., 76 DTC 6156, [1976] CTC 291 (FCA)

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E.S.G. Holdings Ltd. v. The Queen, 76 DTC 6158, [1976] CTC 295 (FCA)

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Tax Topics - General Concepts - Agency consequences of carrying on business through agent and employees were the same 37

See Also

Muir Cap & Regalia Ltd. v. MNR, 91 DTC 533 (TCC)

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Newton Ready-Mix Ltd. v. MNR, 89 DTC 595 (TCC)

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92 C.R. - Q.50

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Tax Topics - Income Tax Act - Section 125 - Subsection 125(1) 15

29 June 1992 T.I. 920958 (December 1992 Access Letter, p. 25, ¶C117-178)

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90 C.R. - Q56

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October 1989 Revenue Canada Round Table - Q.15 (Jan. 90 Access Letter, ¶1075)

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October 1989 Revenue Canada Round Table - Q.17 (Jan. 90 Access Letter, ¶1075)

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IT-73R4 "The Small Business Deduction - Income from an Active Business, a Specified Investment Business and a Personal Services Business".

Personal Services Business

Cases

Dynamic Industries Ltd. v. Canada, 2005 DTC 5293, 2005 FCA 211

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See Also

Ivan Cassell Limited v. The Queen, 2016 TCC 53

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C. J. McCarty Inc. v. The Queen, 2015 TCC 201

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9016-9202 Quebec Inc. v. The Queen, 2014 TCC 281

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) CRA used penalty as lever to terminate tax avoidance structure 177

G & J Muirhead Holdings Ltd. v. The Queen, 2014 DTC 1067 [at 3009], 2014 TCC 49 (Informal Procedure)

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Gomez Consulting Ltd. v. The Queen, 2013 DTC 1125 [at 670], 2013 TCC 135 (Informal Procedure)

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9098-9005 Quebec Inc. v. The Queen, 2012 DTC 1284 [at 3864], 2012 TCC 324

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Peter Cedar Products Ltd. v. The Queen, 2009 DTC 1314, 2009 TCC 463

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Robertson v. The Queen, 2009 DTC 679, 2009 TCC 183

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489599 B.C. Ltd v. The Queen, 2008 DTC 4107, 2008 TCC 332

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Carreau v. The Queen, 2008 DTC 3106, 2006 TCC 20

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 110

W. B. Pletch Company Limited v. The Queen, 2006 DTC 2065, 2005 TCC 400

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Galaxy Management Ltd. v. The Queen, 2005 DTC 1558, 2005 TCC 674

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S & C Ross Enterprises Ltd. v. The Queen, 2002 DTC 2078 (TCC)

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Bruce E. Morley Law Corp. v. The Queen, 2002 DTC 1547 (TCC)

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Placements Marcel Lapointe Inc. v. MNR, 93 DTC 821 (TCC)

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Société de Projets ETPA Inc. v. MNR, 93 DTC 516 (TCC)

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IT-73R4 "The Small Business Deduction - Income from an Active Business, a Specified Investment Business and a Personal Services Business".

IT-168R3 "Athletes and Players Employed by Football, Hockey and Similar Clubs" under "Personal Services Business" and under "Endorsements and Public Appearances"

Articles

Michael Gemmiti, "Placement Agencies: Insurable and Pensionable Employment", Canadian Tax Highlights", Vol. 22, No. 3, March 2014, p. 10.

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Specified Corporate Income

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20 April 2017 External T.I. 2016-0679721E5 - The small business deduction

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Paragraph (a)

Subparagraph (a)(i)

Articles

Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017

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Paragraph (b)

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13 June 2017 STEP Roundtable Q. 1, 2017-0693461C6 - Specified corporate income

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Specified Investment Business

Cases

Weaver v. Canada, 2008 DTC 6517, 2008 FCA 238

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation previous active business not relevant 91

Baker v. Canada, 2005 DTC 5266, 2005 FCA 185

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Lerric Investments Corp. v. Canada, 2001 DTC 5169, 2001 FCA 14

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See Also

0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231

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Words and Phrases
principal purpose
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Tax Topics - General Concepts - Onus Minister's pleading of assumptions of law does not relieve taxpayer from entering a case 98

R&C Commrs v. Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)

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Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business actively-managed rental property an investment business 385

Langille v. The Queen, 2009 DTC 1103 [at 564], 2009 TCC 139

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Lee v. The Queen, 99 DTC 925 (TCC)

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Ben Raedarc Holdings Ltd. v. The Queen, 98 DTC 1218 (TCC)

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Rogers v. The Queen, 97 DTC 890 (TCC)

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Canwest Capital Inc. v. The Queen, 97 DTC 1 (TCC)

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Tax Topics - Income Tax Act - Section 129 - Subsection 129(1.2) 85

Crompton v. The Queen, 96 DTC 1700 (TCC)

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The Queen v. Hughes & Co. Holdings Ltd., 94 DTC 6511

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4 February 1994 T.I. 932524 (C.T.O. "Small Business Corporation")

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91 C.R. - Q.31

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21 August 1991 T.I. (Tax Window, No. 8, p. 18, ¶1400)

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26 June 1991 T.I. (Tax Window, No. 4, p. 25, ¶1316)

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26 February 1990 T.I. (July 1990 Access Letter, ¶1332)

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19 September 89 T.I. (February 1990 Access Letter, ¶1123)

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11 September 89 T.I. (February 1990 Access Letter, ¶1123)

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88 C.R. - Q.51

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81 C.R. - Q.30

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IT-73R4 "The Small Business Deduction - Income from an Active Business, a Specified Investment Business and a Personal Services Business".

Specified partnership income

Administrative Policy

6 May 2016 External T.I. 2016-0646411E5 - Professional corporation & small business deduction

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2012 Ruling 2011-0392041R3 - Incorporation of a Professional Partnership

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(3) non s. 85(2) property allocated exclusively to liability assumption, and share/note consideration pre-allocated 310

2013 Ruling 2013-0498961R3 - Partner creating a professional corporation

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(2.1) incorporated partners of professional partnership 106

25 February 2014 External T.I. 2012-0448431E5 - Reporting of Income by Estate

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2012 Ruling 2012-0447491R3 - Professional corporation contracting with partshp

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2011 Ruling 2011-0407891R3 - Professional corporation contracting with partnership

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Paragraph (c)

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Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017

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Subsection 125(10)

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29 November 2016 CTF Roundtable Q. 15, 2016-0669731C6 - The New SBD provisions

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Tax Topics - Income Tax Act - Section 129 - Subsection 129(6) sharing of business limit where no specified income 51