Subsection 125.4(1) - Definitions
Assistance
Administrative Policy
5 February 1998 External T.I. 9729535 - ASSISTANCE
Discussion of circumstances in which loans to finance a production would be considered to be forgivable loans.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | loan repayable out of revenues | 65 |
Paragraph (a)
Administrative Policy
16 May 2005 Internal T.I. 2005-0119061I7 F - Montant d'aide-actions
Prod Co, a wholly owned subsidiary of M Co and a "qualified corporation," produces a Canadian film or video production ("CFVP") at a cost of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subpargraph 12(1)(x)(viii) | funding of film production company by shares rather than loan would not give rise to assistance | 181 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation - Paragraph (a) | conversion of loan that was taxable assistance under s. 12(1)(x) into shares with lower FMV would not give rise to forgiven amount | 304 |
| Tax Topics - Income Tax Regulations - Regulation 1106 - Subsection 1106(1) - Excluded Production - Paragraph (a) - Subparagraph (a)(iii) | transfer of all the revenues to a film implies a transfer of its copyright | 191 |
| Tax Topics - General Concepts - Ownership | transfer of the economic benefit of copyright entails transfer of its ownership | 149 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) | subscription for shares of sub at overvalue constitutes a contribution of capital, generating a s. 53(1)(c) basis bump | 80 |
Qualified Corporation
See Also
Global Video Inc. v. The Queen, 2008 DTC 2621, 2005 TCC 742 (Informal Procedure)
An assessment of the Minister to deny the taxpayer credits on the basis that only about 25% of its total production costs were costs of eligible...
Administrative Policy
2012 Ruling 2011-0426581R3 - Loss and XXXXXXXXXX tax consolidation
Creditco is an indirect subsidiary of Parentco, which is a Canadian corporation. Creditco carries on business in one province, has non-capital...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | loss shift does not detract from principal business | 189 |
Subsection 125.4(3) - Tax credit
Articles
Bacal, Jadd, Thivierge, "Raised the Curtain for Act II: Tax Shelter Reform and the New Film Tax Credit Regime", 1995 Canadian Tax Journal, Vol. 43, No. 6, p. 1965.
Subsection 125.4(4) - Exception
Administrative Policy
9 July 1998 External T.I. 9817185 - TVC INSURANCE AND INVESTOR RULES
In a situation where a loan is made to finance a Canadian film production, although the lender will be an investor it would be viewed as being...
28 September 1998 External T.I. 9819755 - CANADIAN FILM OR PRODUCTION TAX CREDIT
An investment in shares of a Canadian producer will not normally cause a reduction in the amount of the credit available to the producer.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 27 |