See Also
Brock v. MNR, 91 DTC 1079, [1991] 2 CTC 2121 (TCC)
Lamarre Proulx J. rejected a submission that under the laws of Ontario interim accounts rendered by a solicitor are not enforceable and, in any...
Administrative Policy
26 March 2018 External T.I. 2017-0734381E5 F - Election paragraph 34(a)
A professional partnership (Partnership) with a calendar taxation year end makes the s. 34 election for the 2017 year. If a partner transfer’s...
28 May 2014 External T.I. 2014-0531461E5 - Paralegals and work in progress election
[T]he province of Ontario and the Law Society of Upper Canada have created a two tiered system: the practice of law by barristers and solicitors...
15 October 2013 Internal T.I. 2013-0491951I7 F - Travaux en cours au moment du retrait d'un associé
On June 30 of Year 1, individual partners of a Canadian professional partnership who have made the s. 34 election in accordance with s. 96(3)...
13 August 2013 External T.I. 2012-0471401E5 F - FMV - partnership interest
CRA indicated that in determining the FMV of an interest in a professional partnership that had been transferred on a s. 85(1) rollover basis,...
5 January 2009 External T.I. 2008-0294011E5 F - Choix d'exclure les travaux en cours
A newly incorporated corporation at the end of its first year of operating a professional business, had work in progress ("WIP") with a billable...
24 June 2005 External T.I. 2004-0109201E5 F - Professions libérales - Travaux en cours
Can a partnership make the s. 34 election where it carries on a single business but earns income from two types of activities, one of which is not...
18 May 2004 External T.I. 2004-0069691E5 F - Incorporation des professionnels
Can a corporation with accountant shareholders use the s. 34 election where it is carrying on an insolvency practice? CRA responded:
[A]...
25 August 1992 T.I. 921739 (April 1993 Access Letter, p. 136, ¶C20-1143; Tax Window, No. 23, p. 17, ¶2139)
The s. 34 election is not available to a taxpayer who carries on an insolvency practice as his primary practice, rather than as an incidental part...
20 September 1991 T.I. (Tax Window, No. 9, p. 22, ¶1464)
No s. 34 election is available for the business of a patent agency even if the business is carried on by a partnership of which a lawyer is a...
19 September 89 T.I. (February 1990 Access Letter, ¶1104)
The total cost of professional labour including employee benefits will be work in progress, but fixed or indirect overhead costs such as rental,...
IT-471R "Merger of Partnerships" under "Work in Progress"
IT-457R "Election by Professionals to Exclude Work in Progress from Income" under "Meaning of 'Work in Progress'"
Articles
Joint Committee, "Proposed Amendments to Taxation of Work in Progress ("WIP") for Professionals", Letter of 31 May 2017
A longer transitional period than two years may be warranted respecting the phasing out of the deferral under s. 34 given that many of the primary...