Section 125.1

Subsection 125.1(3) - Definitions

Canadian Manufacturing and Processing Profits

Cases

Canada v. Irving Oil Ltd., 2002 DTC 6716, 2001 FCA 364

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Allarcom Pay Television Limited v. The Queen, 98 DTC 6646 (FCA)

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Publi-Hebdos Inc. v. The Queen, 95 DTC 5547 (FCTD)

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The Queen v. International Petrodata, Inc., 95 DTC 5335 (FCA)

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The Queen v. Lehmann Bookbinding Ltd., 95 DTC 5063 (FCTD)

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The Queen v. Veritas Seismic (1987) Ltd., 94 DTC 6123 (FCA)

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Harvey C. Smith Drugs Ltd. v. The Queen, 95 DTC 5026 (FCA)

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Stowe-Woodward Inc. v. The Queen, 92 DTC 6149 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 39

Rolls-Royce (Canada) Ltd. v. The Queen, 91 DTC 5579 (FCTD), aff'd 93 (DTC) 5031 (FCA)

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Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA)

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Words and Phrases
manufacturing processing

Reg Rad Tech Ltd. v. The Queen, 90 DTC 6350 (FCTD), aff'd 91 D.T.C 5518 (FCA)

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The Queen v. Nowsco Well Service Ltd., 90 DTC 6312 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Resolving Ambiguity 30

Dixie X-Ray Associates Ltd. v. The Queen, 88 DTC 6076 (FCTD)

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Canadian Marconi v. R., 86 DTC 6526, [1986] 2CTC 465, [1986] 2 S.C.R. 522

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Halliburton Services Ltd. v. The Queen, 85 DTC 5336, [1985] 2 CTC 52 (FCTD), aff'd 90 DTC 6320 (FCA).

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Crown Tire Sevice Ltd. v. The Queen, 83 DTC 5426, [1983] CTC 412 (FCTD)

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Levi Strauss of Canada, Inc. v. The Queen, 82 DTC 6070, [1982] CTC 65 (FCA)

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Canadian Clyde Tube Forgings Ltd. v. The Queen, 82 DTC 6041, [1982] CTC 21 (FCA)

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McGraw-Hill Ryerson Ltd. v. The Queen, 80 DTC 6211, [1980] CTC 280, aff'd 82 DTC 6142, [1982] CTC 167 (FCA)

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Modern Miss Sportswear Ltd. v. The Queen, 80 DTC 6390, [1980] CTC 521 (FCTD)

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MDS Health Group Ltd. v. The Queen, 79 DTC 5279, [1979] CTC 337 (FCTD)

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Canadian Wirevision Ltd. v. The Queen, 79 DTC 5101, [1979] CTC 122 (FCA)

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See Also

C.R.I. Environnement Inc. c. La Reine, 2008 DTC 3787, 2007 TCC 206, aff'd 2008 DTC 2471, 2008 FCA 103

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TDS Group Limited v. The Queen, 2005 DTC 786, 2005 TCC 40

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Irving Oil Ltd. v. The Queen, 2000 DTC 2164 (TCC)

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Cintas Canada Ltd. v. The Queen, 99 DTC 926 (TCC)

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Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506 (TCC)

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Mont-Sutton Inc. v. The Queen, 96 DTC 1472 (TCC)

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Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889 (TCC)

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Hope Brook Gold Inc. v. Minister of Finance of Newfoundland (1992), 96 DLR (4th) 114 (Nfld. C.A.)

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International Petrodata Inc. v. The Queen, 93 DTC 110 (TCC)

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Tuyauteries Saglac Inc. v. MNR, 93 DTC 40 (TCC)

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Versa Services Ltd. v. MNR, 92 DTC 1769 (TCC)

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Industrial Forest Reserves Ltd. v. MNR, 92 DTC 1060 (TCC)

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Design One Creative Graphic Productions Ltd. v. MNR, 92 DTC 1006 (TCC)

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Calgary Television Ltd. v. MNR, 90 DTC 1577 (TCC)

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Fiat Auto Canada Ltd. v. The Queen, 83 DTC 5451, [1983] CTC 432 (FCTD)

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Royal Bank of Canada v. Deputy Minister of National Revenue for Customs and Excise, 81 DTC 5301, [1982] CTC 183, [1981] 2 S.C.R. 139

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Words and Phrases
manufacture

Controlled Foods Corp. Ltd. v. The Queen, 80 DTC 6369, [1980] CTC 491 (FCA)

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The Queen v. York Marble, Tile and Terrazzo Ltd., [1968] S.C.R. 140, [1968] CTC 44, 68 DTC 5001

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Words and Phrases
manufacture
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Similar Statutes Customs Tariff legislation was in pari materia to the Excise Tax Act 374

Biltrite Tire Co. v. The King, [1937] S.C.R. 364, 1 D.T.C. 360

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Words and Phrases
produce manufacture

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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25 March 2013 External T.I. 2012-0470501E5 - Manufacturing and processing

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26 March 2001 External T.I. 2001-007349 -

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21 March 1996 Memorandum 960592 (C.T.O. "Interest on Overpayment and Adjusted Business Income")

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8 March 1993 T.I. (Tax Window, No. 29, p. 4, ¶2446)

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2 March 1993 T.I. (Tax Window, no. 29, p.18, ¶2450)

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91 C.R. - Q.33

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25 July 1991 T.I. (Tax Window, No. 7, p. 18, ¶1373)

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18 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 26, ¶1097)

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88 CPTJ - Q.10

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79 C.R. - Q.21

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IT-145R "Canadian Manufacturing and Processing Profits - Reduced Rate of Corporate Tax".

manufacturing or processing

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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15 January 2015 External T.I. 2014-0548101E5 F - Sens de "fabrication ou transformation"

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 “primarily” based on the fraction of time used in the qualifying activities 104

(a)

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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(b)

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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(c)

Cases

Nova Construction Co. Ltd. v. The Queen, 85 DTC 5594, [1986] 1 CTC 68 (FCA)

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See Also

Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889 (TCC)

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Chateau Manufacturing Ltd. v. Dep. MNR, 84 DTC 6126, [1984] CTC 43 (FCA)

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Administrative Policy

14 February 2014 External T.I. 2013-0504601E5 F - Bénéfices de fabrication et de transformation

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Separate Existence avoidance through M&P carried on through related corp 31

(d)

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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(h)

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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(e)

See Also

Continental Lime Ltd. v. The Queen, 99 DTC 1154 (TCC)

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(i)

See Also

Nova Construction Sand and Gravel Ltd. v. The Queen, 80 DTC 6298, [1980] CTC 378 (FCA)

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Manufacturing or Processing (l)

Cases

Range Grain Co. Ltd. v. The Queen, 97 DTC 5221 (FCTD)

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Qit-Fer et Titane Inc. v. The Queen, 92 DTC 6071 (FCTD), aff'd on different grounds 96 DTC 6213 (FCA)

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Crown Tire Sevice Ltd. v. The Queen, 83 DTC 5426, [1983] CTC 412 (FCTD)

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See Also

Le Soleil Limitée v. MNR, 73 DTC 5093, [1973] CTC 91 (FCA)

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