(1)-(16)

Table of Contents

Subsection 13(1) - Recaptured depreciation

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

29 July 2015 Internal T.I. 2015-0575921I7 - Recapture arising in statute-barred years

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 13 - Subsection 13(21) - Undepreciated Capital Cost - E negative UCC balance arising in statute-barred year becomes recapture in 1st open year 251
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) negative UCC balance arising in statute-barred year becomes recapture in 1st open year 155

5 October 2012 Roundtable, 2012-0453201C6 F - Règles d'attribution- séparation & décès

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 74.5 - Subsection 74.5(3) s. 74.5(3) busting of attribution occurs even if they were living separate and apart for under 90 days before the death to the transferee common-law spouse 259

15 December 2011 Internal T.I. 2011-0413891I7 F - Récupération d'amortissement-Recapture CCA

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 129 - Subsection 129(4) - Income or Loss reasonable to pro-rate recapture of depreciation between active business income and property income based on relative periods of use 230

Subsection 13(4) - Exchanges of property

Cases

Posno v. The Queen, 89 DTC 5423 (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.

The Queen v. G.T.E. Sylvania Canada Ltd., 74 DTC 6673, [1974] CTC 751 (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

Gestions Calce Ltée v. Agence du revenu du Québec, 2019 QCCQ 7377

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
principally
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property property was used more than 50% in active business of related lessee given actual use (in excess of written lease terms) 321

Administrative Policy

4 November 2016 External T.I. 2016-0666901E5 - New Class 14.1 and replacement property rules

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 248 - Subsection 248(1) - Former Business Property farm quota or other former ECP excluded 46

84 C.R. - Q.85

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.

80 C.R. - Q.44

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 13(4.1) - Replacement for a former property

Administrative Policy

3 December 2019 CTF Roundtable Q. 14, 2019-0824481C6 - Replacement Property Rules

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 44 - Subsection 44(5) a replacement property can be acquired before disposing of the former property 133

1996 Tax Executives Institute Round Table, Q. XIV (No. 5 - 963910)

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 February 1990 T.I. (July 1990 Access Letter, ¶1321)

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 44 - Subsection 44(5) 35

Paragraph 13(4.1)(b)

Subsection 13(4.3)

Subsection 13(5) - Reclassification of property

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

30 June 2000 External T.I. 1999-0013945 - Rental 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.

10 April 1997 External T.I. 9704225 - RENTAL 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.
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1ac) non-arm's length transfer followed by rental 112

7 June 1993 External T.I. 9308775 F - BIEN LOCATIF

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 August 1990 T.I. 900372

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 1101 - Subsection 1101(1ac) 13(5) applies to move to separate class upon becoming a ental property 117

Subsection 13(5.1) - Rules applicable

Administrative Policy

S4-F7-C1 - Amalgamations of Canadian Corporations

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 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 113
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 167
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 157
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 103
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 88
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 172
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 495
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 113
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 165
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 87
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 66
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 120
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 55
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 297
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 758
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 113
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 149
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 139
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 169
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 44
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 346
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 189
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 281
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 191
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 230
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 122
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 62
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 137
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 467
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 371
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 327
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 136
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 179

3 May 2000 T.I. 993323

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 January 1997 External T.I. 9640135 - SUBSECTION 13(5.1) 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.

30 August 1989 T.I. AC 58003

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 13(5.2) - Deemed cost and depreciation

Administrative Policy

2 April 2013 External T.I. 2012-0470591E5 F - Sale of automobile acquired after being leased

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 13 - Subsection 13(5.2) - Paragraph 13(5.2)(b) the deemed s. 13(5.2)(b) cost addition is recognized for s. 13(2) purposes 90

IT-233R "Lease-Option Agreements; Sale-Leaseback Agreements"

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 13(5.2)(b)

Administrative Policy

2 April 2013 External T.I. 2012-0470591E5 F - Sale of automobile acquired after being leased

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 13 - Subsection 13(5.2) s. 13(5.2)(b) addition must be taken into account for s. 13(2) purposes, including re no recapture 172

Subsection 13(5.4) - Idem [Deemed recapture]

Articles

Atlas, "Income Tax Issues in Real Estate Leasing", 1989 Corporate Management Tax Conference, p. 3:18

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 13(6) - Misclassified property

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317

IT-190R2 "Capital Cost Allowance - Transferred and Misclassified Property".

21 November 1991 T.I. (Tax Window, No. 13, p. 5, ¶1604)

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 13(7) - Rules applicable

Paragraph 13(7)(a)

Cases

C.A.E. Inc. v. Canada, 2013 DTC 5084 [at 5944], 2013 FCA 92

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 June 2015 Internal T.I. 2014-0553731I7 - Deduction of Terminal Loss - Wind-up

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 20 - Subsection 20(1) deemed depreciable property in fact not used for income-producing purpose 199
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) depreciable property of sub deemed to be depreciable property when acquired by parent 444

26 November 2013 Annual CTF Roundtable, 2013-0493811C6 - Change in use

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 45 - Subsection 45(1) - Paragraph 45(1)(a) CAE not followed 135

IT102R2 "Conversion of property, other than real property, from or to inventory" 22July 1985

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.

IT-218R "Profit, Capital Gains and Losses from the Sale of Real Estate, including Farmland and Inherited Land and Conversion of Real Estate from Capital Property to Inventory and Vice Versa".

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 13(7)(b)

Administrative Policy

10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme »

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 248 - Subsection 248(1) - Automobile a passenger vehicle ceases to qualify as such when it commences to be used as a taxi given the s. 13(7)(b) deemed acquisition 102

29 June 1995 Internal T.I. 9511027 - CHANGE IN USE

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 13(7)(c)

Administrative Policy

3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef

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 15 - Subsection 15(1) benefits from personal use of corporate aircraft based on the cost of similar benefit from arm's length supplier 174
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 170
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 857

September 1991 Memorandum (Tax Window, No. 9, p. 22, ¶1456)

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 13(7)(e)

See Also

7958501 Canada Inc. v. Agence du revenu du Québec, 2020 QCCQ 2424

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 1102 - Subsection 1102(1) - Paragraph 1102(1)(d) s. 37 claims in developing software precluded it from being depreciable property 179
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element E software created through currently deductible salary expense was disposed of as eligible capital property rather than depreciable property 296

Administrative Policy

20 November 2012 External T.I. 2012-0463191E5 F - Acquisition - personne ayant lien de dépendance

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 January 2017 External T.I. 2015-0576751E5 F - Trust, Disposition of depreciable property, Assumption

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 - 101-110 - Section 107 - Subsection 107(2) s. 107(2) generally available where beneficiary assumes trust debt 168
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Personal Trust non-commital as to whether assumption of debt could constitute tainting consideration 183
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) s. 13(7)(e) applicable to depreciable property distribution 123
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) trust cannot have a NAL relationship with itself 41

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

25 September 1996 External T.I. 5-962794 -

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.

23 May 1996 External T.I. 9604655 - DEEMED REACQUISITION - WHETHER NON-ARM'S LENGTH

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 June 1994 External T.I. 9325685 - TRANSFER OF PROPERTY TO A PARTNER

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 July 1991 T.I. (Tax Window, No. 8, p. 18, ¶1430)

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 December 1989 T.I. (May 1990 Access Letter, ¶1223)

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.

Subparagraph 13(7)(e)(i)

Administrative Policy

4 January 2012 Internal T.I. 2011-0408081I7 F - Transactions entre une société et ses actionnaires

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.

Subparagraph 13(7)(e)(ii)

Administrative Policy

2019 Ruling 2018-0772921R3 - Loss utilization

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 1102 - Subsection 1102(14) Class 14.1 property character maintained in circular-transfer transactions 265
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(b) self-cancelling circular transaction to convert net capital losses into stepped-up UCC 85

Paragraph 13(7)(f)

Articles

Ralph Neville, "Acquisition of Control and Corporate Losses", 1992 Conference Report (CTF), C. 25

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 13(7)(g)

Administrative Policy

5 October 2018 APFF Roundtable Q. 16, 2018-0768871C6 F - Dépenses de bureau à domicile et d’automobile

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 13 - Subsection 13(21) - Undepreciated Capital Cost - A capital cost of co-ownership interest 68
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property depreciable property must be owned 72
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense payment of expenses of taxpayer by another does not preclude “incurring” by taxpayer 169
Tax Topics - Income Tax Act - Section 9 - Nature of Income payment of taxpayer’s expenses by another might give rise to s. 9 or 80 inclusion 187

7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais

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 6 - Subsection 6(1) - Paragraph 6(1)(e) use of manufacturer’s electricity-use standard 94
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A installation cost included 37
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost not reduced under general principles by government assistance 139

Subsection 13(7.1) - Deemed capital cost of certain property

Cases

Prince Albert Pulp Co. Ltd. v. The Queen, 92 DTC 6189 (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
deducted

Canadian Pacific Ltd. v. The Queen, 88 DTC 6265, [1988] 1 CTC 429 (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 248 - Subsection 248(28) 41

The Queen v. AEL Microtel Ltd., 86 DTC 6348, [1986] 2 CTC 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.

Consumers' Gas Co. Ltd. v. The Queen, 86 DTC 6132, [1986] 1 CTC 380 (FCTD), aff'd 87 DTC 5008, [1987] 1 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.
Words and Phrases
assistance
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Compensation Payments recurring compensation for moving capital assets on capital account 101

The Queen v. British Columbia Forest Products Ltd., 85 DTC 5577, [1986] 1CTC 1 (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
receive
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Context 81

Consumers' Gas Company Ltd. v. The Queen, 82 DTC 6300, [1982] CTC 339 (FCTD), aff'd, 84 DTC 6058, [1984] CTC 83 (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
subsidy

Fonthill Lumber Ltd. v. The Queen, 81 DTC 5333, [1981] CTC 406 (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.

Ottawa Valley Power Co. v. MNR, 69 DTC 5166, [1969] CTC 242 (Ex Ct), aff'd 70 DTC 6223, [1970] CTC 305, [1970] S.C.R. 941

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 April 2014 External T.I. 2014-0521041E5 F - Application de 13(7.1)

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.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.4) general requirements for s. 13(7.4) to apply 207

31 January 2013 Internal T.I. 2012-0466641I7 F - Réduction du coût en capital d'un bien

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 September 2011 External T.I. 2010-0389011E5 F - L'interprétation de " est en droit de recevoir"

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
entitled to receive

12 October 1992 External T.I. 5-922359 -

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 September 1990 Memorandum 902190

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

Paragraph 13(7.1)(f)

Administrative Policy

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 127 - Subsection 127(9) - Government Assistance Quebec investment tax credit is government assistance 46

Subsection 13(7.2)

Administrative Policy

7 June 2010 External T.I. 2009-0331731E5 F - CII et crédit de taxe sur le capital 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.

Subsection 13(7.4) - Deemed capital cost

See Also

GMAC Leaseco Corporation v. The Queen, 2015 DTC 1141 [at 908], 2015 TCC 146

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) amount subject to potential repayment obligation was not received 258
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing capital tax accrued from day to day 226
Tax Topics - Income Tax Act - Section 9 - Compensation Payments payments received in consideration for reducing lease payments were compensation for lost lease income, and s. 9 income 284
Tax Topics - Income Tax Act - Section 9 - Computation of Profit surcharges received by lessor at lease termination for excess use were income 264
Tax Topics - Income Tax Act - Section 9 - Timing inducement payments received by lessor from manufacturer not income until potential repayment obligation quantified 221

Administrative Policy

2 April 2014 External T.I. 2014-0521041E5 F - Application de 13(7.1)

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.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) no s. 13(7.4) election required where s. 13(7.1) applies 123

4 May 1992 Tax Executive's Roundtable, Question 11 (December 1992 Access Letter, p. 48)

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.

27 February 1991 Memorandum (Tax Window, Prelim. No. 3, p. 25, ¶1131; July 1991 Access Letter)

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.

IT-273R2, "Government Assistance - General Comments," para. 12

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 13(7.5) - Deemed capital cost

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

Paragraph 13(7.5)(b)

Administrative Policy

27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures

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 17 access road to quarry was Class 17 property notwithstanding that not owned 164
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(g) ordinary meaning of "mineral" 43
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures expenditures deductible where incurred prior to acquisition decision 154

25 January 2012 External T.I. 2011-0426921E5 - Treatment of expenditures for constructing a road

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 13(9)

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

16 September 2011 Internal T.I. 2010-0383571I7 - Transfer of Property to a US Head Office

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 13(16) - Election concerning vessel

Administrative Policy

16 August 1995 External T.I. 9512405 - VESSELS - PARTIAL DISPOSITION & 13(16) ELECTION

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.