Section 127

Table of Contents

Subsection 127(1) - Logging tax deduction

Qualified Small Business Property

Cases

Kowdrysh v. The Queen, 2001 DTC 5221, 2001 FCA 34

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
acquire

Subsection 127(3) - Contributions to registered parties and candidates

Cases

Doyle v. The Queen, 89 DTC 5030, [1989] 1 CTC 113 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Stasiuk v. The Queen, [1986] 2 CTC 346 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

28 October 1991 Memorandum (Tax Window, No. 12, p. 24, ¶1556)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(4.1) - Monetary contributions — form and content

Administrative Policy

13 October 1994 Internal T.I. 9420847 - CONTRIBUTIONS TO POLITICAL PARTIES BY WAY OF CREDIT CARD

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(5) - Investment tax credit

Cases

AEL Microtel Ltd. v. The Queen, 84 DTC 6374, [1984] CTC 387 (FCTD), rev'd 86 DTC 6348, [1986] 2CTC 108 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

93 C.R. - Q. 5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

86 C.R. - Q. 73

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Hiltz, "Income Earned or Realized: Some Reflections", 1991 Conference Report, c. 15.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) 0

Subsection 127(8) - Investment tax credit of partnership

Cases

Canadian Solifuels Inc. v. The Queen, 2001 DTC 5565, 2001 FCA 280

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Allcolour Paint Ltd. v. The Queen, 97 DTC 5266 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Peter Lee, "Flow-Through of Partnership R & D Tax Credits to Partners", Business Vehicles, Vol. III, No. 4, 1997, p. 150.

Subsection 127(8.1) - Investment tax credit of limited partner

Administrative Policy

86 C.R. Q. 2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(8.3)

Administrative Policy

6 July 2011 Internal T.I. 2010-0357461I7 F - CII RS&DE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(9) - Idem [Definitions]

Apprenticeship Expenditure

Administrative Policy

19 August 2008 Internal T.I. 2008-0280681I7 F - Création d'emplois d'apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Certified Property

Cases

Fibre Co. Pulp Inc. v. The Queen, 94 DTC 6325, [1994] 2 CTC 114, [1994] 2 CTC 2131, 94 DTC 1543, [1994] 2 CTC 2153, 94 DTC 1809 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Sudbrack v. The Queen, 2000 DTC 2521, Docket: 98-2386-IT-G (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

22 March 1990 T.I. (August 1990 Access Letter, ¶1382)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Child Care Space Amount

Administrative Policy

16 May 2014 External T.I. 2014-0526161E5 F - CII des places en garderie

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Contract Payment

See Also

MDA Systems Ltd. v. Agence du revenu du Québec, 2020 QCCQ 4190

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Comdev Ltd. v. The Queen, 99 DTC 775 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Eligible Apprentice

Administrative Policy

7 June 2016 External T.I. 2014-0532451E5 F - Crédit pour la création d’emplois pour apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

26 September 2008 Internal T.I. 2008-0281111I7 F - Salaires admissibles - CICEA

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1 May 2008 External T.I. 2007-0250141E5 F - Crédit pour la création d'emplois d'apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 April 2008 External T.I. 2007-0257041E5 F - Crédit pour la création d'emplois d'apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
year
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 37 - Subsection 37(1) “year” refers to any 12-month period 133

9 April 2008 Internal T.I. 2008-0268881I7 F - Crédit d'impôt pour apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

18 February 2008 External T.I. 2007-0228491E5 F - Heures travaillées hors décret de la CCQ

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 May 2007 External T.I. 2007-0228611E5 F - Crédit pour la création d'emplois pour apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
year contract

First Term Shared-Use Equipment

Administrative Policy

9 February 2010 External T.I. 2009-0316561E5 F - Biens en immobilisations-RS&DE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(11) requirement during establishment phase to be used primarily during useful life for SR&ED 63

Flow-Through Mining Expenditure

Articles

Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips", 2015 CTF Annual Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Government Assistance

Cases

Immunovaccine Technologies Inc. v. Canada, 2014 DTC 5119 [at 7309], 2014 FCA 196, aff'g 2013 DTC 1101 [at 531], 2013 TCC 103

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) government loans made in a non-commercial capacity are "government assistance" 100
Tax Topics - Statutory Interpretation - Ejusdem Generis definition ending in "any other form of assistance" precluded a narrow reading 82

The Queen v. CCLC Technologies Inc., 96 DTC 6527 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) governmnt receipt in non-commercial arrangement was assistance etc. 149

See Also

Agence du revenu du Québec v. PCI Géomatics Entreprises Inc., 2020 QCCA 1342

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

PCI Géomatics Entreprises Inc. v. Agence du revenu du Québec, 2019 QCCQ 2688, rev'd 2020 QCCA 1342

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
forgivable loan

Administrative Policy

21 June 2013 Internal T.I. 2012-0459731I7 - Government Assistance

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 June 2010 External T.I. 2009-0350241E5 F - Crédit d'impôt pour investissement du Québec

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(vi) Quebec investment tax credit is deducted under s. 13(7.1) rather than included under s. 12(1)(x) 90
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) - Paragraph 13(7.1)(f) Quebec investment tax credit reduces capital cost at end of year for which it is claimed, excepting any carryforward portion 213

Investment Tax Credit

See Also

Easy Way Cattle Oilers Ltd. v. The Queen, 2015 TCC 211

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Papiers Cascades Cabano Inc. c. La Reine, 2006 DTC 2305, 2005 TCC 396

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Datacalc Research Corp. v. The Queen, 2002 DTC 1479 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2 October 1992 Memorandum 921938 (September 1993 Access Letter, p. 421, ¶C117-204)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (a.1)

Administrative Policy

3 November 2008 External T.I. 2008-0278431E5 F - Déménagement hors Canada du siège soc. de société

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) OECD Commentary informs allocation of sales through non-resident office to Cdn manufacturing operation 172
Tax Topics - Income Tax Act - Section 250 - Subsection 250(5) central management and control test overridden 122
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(b) s. 4(1)(b) requires allocation between Canada and another country on basis of relative profit contribution 172

Paragraph (m)

Administrative Policy

26 September 2007 External T.I. 2007-0252621E5 F - Crédit pour la création d'emplois pour apprentis

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Qualified Construction Equipment

Administrative Policy

5 September 1991 Memorandum (Tax Window, No. 10, p. 17, ¶1474)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Qualified Expenditure

Cases

Alcatel Canada Inc. v. The Queen, 2005 DTC 387, 2005 TCC 149

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
expenditure

See Also

Tigney Technology Inc. v. M.N.R., 97 DTC 414 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) 122

Cultures LaFlamme (1984) Inc. v. MNR, 93 DTC 603, [1993] 1 CTC 2634 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
expenditure

G.A. Borstad Associates Ltd. v. MNR, 92 DTC 1743, [1992] 2 CTC 2146 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

7 October 2005 APFF Roundtable Q. 24, 2005-0141141C6 - Stock option benefits and SR&ED tax credit

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Application Policy SR & ED 96-03 "Claimants' Entitlements and Responsibilities".

Paragraph (a)

See Also

Andre Lamy Medicine Professional Corporation v. The Queen, 2020 TCC 61

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency required individual billing to OHIP does not preclude earning of medical practice income by professional corporation 150
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) surgeon carried out his research qua employee of his professional corporation 179

Qualified Property

Cases

Burger King Restaurants of Canada Inc. v. Canada, 2000 DTC 6061 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
primarily

Labrador Offshore Shipping Co. Ltd. v. The Queen, 90 DTC 6096 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
use
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 255 45

Mother's Pizza Parlour (London) Ltd. v. The Queen, 88 DTC 6397, [1988] 2 CTC 197 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Lor-Wes Contracting Ltd. v. The Queen, 85 DTC 5310, [1985] 2 CTC 79 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Mother's Pizza Parlour Ltd. v. The Queen, 85 DTC 5271, [1985] 1 CTC 361 (FCTD), aff'd supra.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

O'Neill v. The Queen, 85 DTC 5026, [1985] 1 CTC 682 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Bunge of Canada Ltd. v. The Queen, 84 DTC 6276, [1984] CTC 284 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Pêcheries Yvon Savage Inc. v. The Queen, 2012 DTC 1059 [at 2781], 2011 TCC 477

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Ateliers Ferroviaires de Mont-Joli Inc. v. The Queen, 2011 DTC 1358 [at 2006], 2011 TCC 352

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Albert v. The Queen, 2009 DTC 1114 [at 603], 2009 TCC 16 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

H.B. Barton Trucking Ltd. v. The Queen, 2009 TCC 376

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Stevenson v. The Queen, 2001 DTC 1019 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Capilano International Inc. v. The Queen, 95 DTC 915, [1996] 1 CTC 2254 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Produits L.B. (1987) Ltée v. The Queen, 93 DTC 1541, [1993] 2 CTC 2625 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Laurent Goulet & Fils Inc. v. MNR, 92 DTC 1611 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Re PPG Industries Canada Ltd. (1984), 10 DLR (4th) 476 (Ont HC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Coca Cola Ltd. v. Dep. MNR, 84 DTC 6081, [1984] CTC 75 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Re Nabisco Brands Ltd. (1984), 45 OR (2d) 602 (SCO), aff'd 53 OR (2d) 736 (Ont. D.C.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Commr. of N.W.T. v. Pine Point Mines Ltd., [1981] 5 WWR 420 (N.W.T.S.C.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Newaygo Forest Products Ltd. v. Min. of Rev. of Ontario, [1981] C.T.C 118 (SCO)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

28 April 2015 External T.I. 2015-0576511E5 - Fishing vessels and Atlantic Investment Tax Credit

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

29 May 2014 External T.I. 2014-0517371E5 - Manitoba Investment Tax Credit

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 July 2013 Internal T.I. 2013-0490091I7 - Qualified Property

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

6 October 2011 External T.I. 2011-0417811E5 - Investment Tax Credit and 16.1(1)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 February 1994 Internal T.I. 9333597 - TRUCKS HAULING WOOD CHIPS - QUALIFIED PROPERTY?

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 May 1991 T.I. (Tax Window, No. 3, p. 29, ¶1254)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

31 May 1990 T.I. (October 1990 Access Letter, ¶1477)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 May 1990 T.I. (October 1990 Access Letter, ¶1476)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 February 1990 T.I. (July 1990 Access Letter, ¶1333)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 January 1990 T.I. (June 1990 Access Letter, ¶1275)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 September 89 T.I. (February 1990 Access Letter, ¶1124)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 255 28

Paragraph (c)

Cases

Stark International Inc. v. The Queen, 2019 TCC 248

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
use
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 oil-processing equipment was for sale even though initial use was to process customer's oil 673

Administrative Policy

20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
primarily
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(27) no ITC reversal if unanticipated transfer of equipment to a farm outside the region 163
Tax Topics - General Concepts - Ownership co-owners entitled to pro rata ITCs 60

Subparagraph (c)(i)

See Also

Environnement Sanivac Inc. v. ARQ, 2016 QCCQ 9461

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 trucks used both for transporting and decanting dirty oil were M&P equipment 138

Qualified Transportation Equipment

Cases

Canada v. McMynn, 97 DTC 5325 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
transport

Specified Percentage

Administrative Policy

19 December 2012 External T.I. 2011-0425581E5 F - CII - régions admissibles-Montérégie-Rive-Sud

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(10.1) - Additions to investment tax credit

Administrative Policy

25 July 1989 Memorandum (Dec. 89 Access Letter, ¶1056)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(10.2) - Expenditure limit determined

Administrative Policy

11 January 2008 External T.I. 2007-0227061E5 F - Revenu imposable sociétés associées non-résidentes

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 June 2012 External T.I. 2011-0417971E5 F - Sociétés associées - CII

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

15 November 2011 External T.I. 2011-0423671E5 - Expenditure Limit

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 January 2008 External T.I. 2007-0232751E5 F - Éléments "A" et "B" du paragraphe 127(10.2)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(5.1) no inclusion of taxable capital regarding associated non-resident with no Canadian PE 226

Subsection 127(10.22)

Administrative Policy

15 January 2010 External T.I. 2009-0343841E5 F - Application du paragraphe 127(10.22)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(11) - Interpretation

Paragraph 127(11)(b)

Administrative Policy

28 May 1991 Memorandum (Tax Window, No. 3, p. 14, ¶1265)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(11.1) - Investment tax credit

See Also

Gaston Cellard Inc. v. The Queen, 2005 DTC 699, 2002 DTC 1890 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 127(11.1)(c)

See Also

Tyoxide Canada Inc. v. The Queen, 93 DTC 1499, [1994] 1 CTC 2569 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

25 August 1994 External T.I. 9417185 - SR&ED

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

19 March 1993 T.I. (Tax Window, No. 29, p. 1 ¶2442)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(11.2) - Time of expenditure and acquisition

Administrative Policy

9 September 1992 T.I. (Tax Window, No. 24, p. 17, ¶2210)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(11.4) - Special rule for eligible salary and wages — apprentices

Administrative Policy

Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)".

Subsection 127(17) - Assessment

Administrative Policy

88 C.R. - Q.45

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(18) - Reduction of qualified expenditures

Administrative Policy

18 July 2001 External T.I. 2001-006967 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 June 1998 External T.I. 9809735 - SR&ED

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

24 September 1997 Internal T.I. 9718257 - INTERPRETATION OF SUBSECTION 127(18) OF THE ACT

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(19) - Reduction of qualified expenditures

See Also

PSC Elstow Research Farm Inc v. The Queen, 2009 DTC 168, 2008 TCC 694

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

Guidance: How the Canada emergency wage subsidy affects SR&ED claims 19 February 2021 CRA Webpage

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 127(27)

Administrative Policy

20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) test is of intention on acquisition to use over 50%, during months of likely use during the equipment’s lifetime, on farm in the region 207
Tax Topics - General Concepts - Ownership co-owners entitled to pro rata ITCs 60