Subsection 1100(0.1)
Paragraph 1100(0.1)(c)
Administrative Policy
24 March 2023 External T.I. 2023-0960171E5 - Immediate expensing rules
Does the amount determined under Reg. 1100(0.1)(c) - the income of an eligible person or partnership (EPOP) earned from a business or property...
Subsection 1100(1)
Paragraph 1100(1)(a.1)
Administrative Policy
9 September 2014 External T.I. 2014-0530631E5 F - Alinéa 1100(1)a.1) du Règlement
A pharmaceutical company carries on SR&ED at a building whose floor space is more than 90% utilized as laboratories for pharmaceutical research...
11 February 2013 External T.I. 2012-0469441E5 F - Aire de plancher - fabrication et transformation
In response to a question as to whether floor space representing a cafeteria, washroom and office qualified, CRA stated (TaxInterpretations...
16 November 2009 Internal T.I. 2009-0342571I7 F - Catégorie 1, alinéa 1100(1)a.1) du Règlement
Which of the owner of the property and the user of an eligible non-residential building will be eligible for CCA under Reg. 1100(1)(a.1)?
The...
Paragraph 1100(1)(c) - Class 14
Cases
Weinberger v. MNR, 64 DTC 5060, [1964] CTC 103 (Ex Ct)
The cost to the taxpayer of a patent included not only the legal expenses incurred in obtaining the patent but also the research-related costs of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 50 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | cost of patent included legal costs and R&D | 63 |
Administrative Policy
2011 Ruling 2010-0374221R3 - XXXXXXXXXX
A limited partnership for the distribution of a film (the "Picture") pursuant to a distribution licence for 10 years contained in a distribution...
27 February 2002 Internal T.I. 2002-0121207 - CLASS 14 - CAPITAL COST ALLOWANCE
Where a class 14 asset that originally was purchased at a cost of $100,000 and had a term of ten years, is disposed of in the fifth year, the...
22 June 2001 Internal T.I. 2001-0065467 - AMORTIZATION OF BROADCAST LICENSES
CCRA is no longer of the view that Regulation 1101(1)(c) require that the capital cost of a property be amortized equally over its life. "[A]...
Paragraph 1100(1)(c.1)
Administrative Policy
13 March 2023 External T.I. 2019-0802271E5 F - Déduction supplémentaire prévue au sous-alinéa 110
Regarding the availability of the additional deduction under Reg. 1100(1)(c.1)(i) where a Class 14.1 property was acquired by a taxpayer after...
8 March 2023 External T.I. 2017-0729871E5 F - Déduction supplémentaire prévue au sous-alinéa 110
Regarding where a taxpayer acquired Class 14.1 property after 2016 pursuant to a s. 85 rollover, CRA noted that, for taxation years ending before...
Paragraph 1100(1)(e)
Administrative Policy
7 November 2011 Internal T.I. 2011-0424641I7 F - Right to cut Christmas trees
A taxpayer purchased the right to cut, over a period of 10 years, Christmas trees on another taxpayer's land for a lump sum payable over 4 years....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Timber Resource Property | right to cut Christmas trees was not a timber resource property | 93 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14 | right to cut Christmas trees with 10-year term was a Class 14 property | 134 |
30 April 2008 External T.I. 2007-0252051E5 F - Commercial Woodlot - Timber Limit
In the context of a general response to a query regarding a taxpayer who was preparing to buy a woodlot, and then log the wood and sell it, CRA...
Paragraph 1100(1)(g) - Industrial Mineral Mines
Administrative Policy
27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures
CRA affirmed: its position in IT-492, (archived), para. 3 that "the word mineral has its ordinary meaning of any chemical or compound occurring...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) - Paragraph 13(7.5)(b) | access road deemed to have been "acquired" | 201 |
| 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 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 |
3 February 2014 External T.I. 2013-0506641E5 - CCA class(es) for mineral claims and mining leases
Volcanic aggregate which was produced by a quarry and sold for various construction purposes likely qualified as industrial minerals. CRA in this...
Paragraph 1100(1)(ta)
Administrative Policy
Weinberger v. MNR, 64 DTC 5060 (Ex Ct)
3 July 1992 T.I. 920476 (January - February Access Letter, p. 12, ¶C20-066)
A Class 24 or 27 property acquired after November 12, 1981 which qualifies under s. 1100(1)(ta)(v) will qualify for write-off over two years.
Paragraph 1100(1)(zg) - Additional Allowance — Year 2000 Computer Hardware and Systems Software
Paragraph 1100(5k.1)
Subsection 1100(1.1)
Administrative Policy
10 July 1991 T.I. (Tax Window, No. 5, p. 19, ¶1342)
An investment tax credit will reduce the UCC of the related property with respect to the calculation under Regulation 1100(1.1)(b), but not under...
Articles
Howick, "Income Tax Aspects of Leasing", Tax Profile, May 1992, p. 211
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) | 0 |
Subsection 1100(1.11)
Administrative Policy
3 February 1997 External T.I. 9640635 - LEASE AND SUB-LEASE
A sublease of property does not cause the property to become intangible property.
17 December 1993 Income Tax Severed Letter 9323875 - Specified Leasing Property Rules
"The circumstances of a particular fact situation will determine whether a sublease causes the property to become 'specified leasing property'. If...
30 March 1993 External T.I. 9308305 F - Specified Leasing Property
"When a corporation derives revenue from the leasing of a vessel on a 'time-charter' basis (i.e., the owner provides all services including fuel,...
Subsection 1100(2) - Property Acquired in the Year
Administrative Policy
6 June 2019 CPTS Roundtable, 2019-0816111C6
CRA confirmed that its statements in Folio S4-F15-C1 as to the meaning of M&P also apply in this context so that, for example, in the oil and gas...
S3-F4-C1 - General Discussion of Capital Cost Allowance
Operation of formula
1.38 Subsection 1100(2) of the Regulations limits CCA in the tax year of acquisition of most depreciable property. The claim...
S4-F7-C1 - Amalgamations of Canadian Corporations
1.31 …[T]he half-year rule found in subsection 1100(2) of the Regulations will apply in determining the new corporation's maximum capital cost...
Articles
Sarah S. Chiu, "Half-Year Rule and Amalgamations", Resource Sector Taxation, Volume IX, No. 2, 2013, p. 638
A textual and contextual interpretation of the half-year rule suggests that the rule may not apply to amalgamations. In particular, the...
Element A
Administrative Policy
21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA
The $10,000,000 capital cost of the Property will be included in the UCC of Class 43.2, based on its date of acquisition. The Property meets the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance | NS CITC was reasonably expected to be received at year end even though required government certificate not yet applied for | 170 |
| Tax Topics - Income Tax Act - Section 127.45 - Subsection 127.45(5) - Paragraph 127.45(5)(b.1) - Subparagraph 127.45(5)(b.1(i)) | combined effect of NS CITC and clean tech ITC | 119 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) | illustration showing recapture being realized with no disposition | 294 |
24 June 2024 External T.I. 2023-1000861E5 - Clean technology property and phase out of AIIP
The only Class 43.1 or 43.2 property transactions of the taxpayer were that it acquired (solar energy) equipment described in Class 43.1(d)(vi) in...
Subsection 1100(2.1)
See Also
McLellan v. M.N.R., 90 DTC 1405, [1990] 2 CTC 2191 (TCC)
Although agreements did not obligate a partnership to acquire any specific property from a particular vendor but only property of a type or class...
Subsection 1100(2.2)
Administrative Policy
S3-F4-C1 - General Discussion of Capital Cost Allowance
Overview
1.41 … [S]ubsection 1100(2.2) … appl[ies] to a transferee only if:
- the property was depreciable property of the transferor, and was...
S4-F7-C1 - Amalgamations of Canadian Corporations
1.31 …[T]he half-year rule found in subsection 1100(2) of the Regulations will apply in determining the new corporation's maximum capital cost...
18 October 2011 External T.I. 2011-0401381E5 - Capital Cost Allowance for a Partnership
None of the exceptions in s. 1100(2.2) to the half-year capital cost allowance rule appear to cover a deemed acquisition of property under s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) | 37 | |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.21) | 30 |
February 1991 TI
Where a corporation ("Pco") transfers depreciable property to a subsidiary ("Subco") and, later in the day, a third party (Aco") acquires all the...
10 August 2004 Internal T.I. 2004-0080201I7 - Capital Cost Allowance
The exception in Regulation 1100(2.2) for non-arm's length acquisitions of depreciable property situated outside Canada did not apply to an...
29 December 1989 T.I. (May 1990 Access Letter, ¶1224)
A partnership is a person and a taxpayer for purposes of ss.1100(2.2) and 1102(14).
89 C.P.T.J. - Q13
A partnership will be considered to be a taxpayer for purposes of s. 1100(2.2)(e) and s. 1102(14)(b). Therefore, those provisions will apply to a...
Paragraph 1100(2.2)(f)
Articles
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report
Non-application of half-year rule on drop-down from lease originator to LP if not inventory (p.12:10)
This exception to the half-year rule may...
Subsection 1100(2.21)
Administrative Policy
18 October 2011 External T.I. 2011-0401381E5 - Capital Cost Allowance for a Partnership
Subsection 1100(2.21) does not apply to the deeming rule in paragraph 96(8)(a) of the Act, because that paragraph only creates a deemed...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) | 37 | |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) | 29 |
22 August 2000 External T.I. 2000-0002885 - SALE/LEASEBACK TRANSACTION
As s. 16.1(1)(b) does not deem a taxpayer to have disposed of an acquired or reacquired property, Regulations 1100(2.21) will not apply to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) | 26 | |
| Tax Topics - Income Tax Regulations - Regulation 1103 - Subsection 1103(2d) | 4 |
Subsection 1100(3)
Administrative Policy
S3-F4-C1 - General Discussion of Capital Cost Allowance
Combined application with half-year rule
1.43 The adjustment for a short-fiscal period applies in addition to the half-year rule. For example, if...
Subsection 1100(4.1)
Administrative Policy
IT-195R4 "Rental Property - Capital Cost Allowance Restrictions"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(11) | 128 | |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(14) | 223 |
Subsection 1100(5k.1)
Administrative Policy
20 May 2008 Internal T.I. 2008-0267041I7 F - Productions cinématographiques et magnétoscopiques
Must a taxpayer include all Canadian film or video productions ("CFVP") productions in a single separate depreciable class, or should a separate...
Subsection 1100(9) - Patents
Administrative Policy
IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) | 18 | |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14 | 283 |
Subsection 1100(11) - Rental Properties
Administrative Policy
IT-195R4 "Rental Property - Capital Cost Allowance Restrictions"
2. Accordingly, if a taxpayer has more than one class of rental properties, the CCA restriction is not applied to the individual classes of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(4.1) | 0 | |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(14) | 223 |
6 February 2008 External T.I. 2007-0239951E5 F - Restrictions à la déduction pour amortissement
S. 75(2) applies to the transfer of one of the individual’s rental properties to a trust. In confirming that the rental property restriction...
Subsection 1100(12)
See Also
Satin Finish Hardwood Flooring (Ontario) Ltd. v. R. I, 97 DTC 287, [1997] 2 CTC 2915 (TCC)
The taxpayer was found to be a principal business corporation notwithstanding that its business of manufacturing unfinished parquet flooring had...
Administrative Policy
2 November 2023 APFF Roundtable Q. 5, 2023-0982821C6 F - Notion d’ « entreprise principale » aux fins du paragraphe 1100(12) R.I.R.
Aco carries on a business of renting its own real estate - as well as holding shares of various operating companies on which it regularly receives...
18 April 2001 External T.I. 2001-0070105 - CCA FOR SHORT FISCAL PERIOD
In response to a suggestion that an individual who started a new business partway through the year was not required to pro-rate capital cost...
27 March 1992 T.I. 920570
A corporation would be considered to be a principal-business corporation if its sole asset is an interest in a principal business partnership.
Subsection 1100(14)
Cases
Gulf Canada Resources Ltd. v. The Queen, 93 DTC 5345, [1993] 2 CTC 198 (FCTD)
A predecessor of the taxpayer ("GCL") approached a developer to erect a large office building in Calgary in order that GCL could eliminate the...
See Also
McInnes v. The Queen, 2014 TCC 247 (Informal Procedure)
The taxpayer owned and operated a rental chalet in Charlevoix Quebec which was furnished including with kitchen utensils, bedding, WiFi and sound...
Sivasubramaniam v. The Queen, 2008 DTC 3886, 2008 TCC 261 (Informal Procedure)
The taxpayer was unsuccessful in a submission that seven condominiums owned by him, which generated gross revenue of approximately $85,000 in a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | hope to dispose of at gain consistent with capital property | 64 |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(b) | 111 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | capital gains from resale not a permitted purpose | 63 |
Jong v. The Queen, 98 DTC 16161 (TCC)
A medical practioner who owned a building in co-ownership with others and used about 45% of the building along with the co-owners in a medical...
Malenfant v. MNR, 92 DTC 2081, [1992] 2 CTC 2431 (TCC)
Various hotels and motels of the taxpayer were rental properties given that the revenues were derived principally from the rental of rooms and not...
Administrative Policy
26 July 2010 External T.I. 2010-0364721E5 F - Revenus de bien et d'entreprise
After concluding that “the operator of a bed and breakfast, who has a personal residence in which bed and breakfast rooms are rented out on a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(12) | bed and breakfast operation was business rather than property source (and thus subject to s. 18(12) limitation) since more than normal essential services provided | 166 |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | reduction of personal expenses is not the pursuit of profit | 97 |
26 April 1990 T.I. (September 1990 Access Letter, ¶1437)
Where one of the assets of a corporation, which together with its subsidiaries carries on an active business, consist of a 60% undivided interest...
IT-195R4 "Rental Property - Capital Cost Allowance Restrictions"
Principally based on time
4. ...[T]he word "principally" means "primarily" or "chiefly." In establishing whether a property is used principally...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(4.1) | 0 | |
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(11) | 128 |
Subsection 1100(14.1)
Administrative Policy
2 August 1990 T.I. 900139
[A] person who operates a hotel is in the business of providing services and not in the rentals business. Although Regulation 1100(14.1) could...
Subsection 1100(15) - Leasing Properties
See Also
McCoy v. The Queen, 2003 DTC 660, 2003 TCC 332
A partnership purchased trading software from a vendor corporation, with the vendor and the partnership agreeing that the vendor would form a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 122 | |
| Tax Topics - General Concepts - Purpose/Intention | intention objectively determined having regard to the material presented to investors | 83 |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 202 | |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.2) - Paragraph 96(2.2)(d) | 118 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | 83 |
Subsection 1100(16)
Administrative Policy
30 October 2003 Internal T.I. 2003-0030597 - ARE SWAP RECEIPTS GROSS REVENUE
The expression "gross revenue" used in Regulation 1100(16)(a) would not include swap receipts received by a potentially qualifying corporation in...
18 December 2002 External T.I. 2002-0156515 - LEASING PROPERTY EXCEPTIONS
"We are of the view that a corporation that carried on two businesses of the type described in subparagraph 1100(16)(a)(ii) of the Regulations,...
19 February 1996 External T.I. 9530915 - LEASING BUSINESS
Gross revenue from the principal business includes proceeds from the sale of property described in Regulation 1100(16) or property of the same...
December 1992 B.C. Tax Executives Institute Round Table, Q. 5 (October 1993 Access Letter, p. 478)
Because a joint venture is not recognized by a statute, each corporate joint venturer must account separately for its gross revenue test under...
31 March 1992 T.I. (Tax Window, No. 18, p. 13, ¶1841)
The fact that a corporation manufactures property that it subsequently sells and leases to its customers will not prevent qualification as a...
26 March 1990 T.I. (August 1990 Access Letter, ¶1396)
Where one of the two principal business corporations of a principal business partnership acquired its partnership interest upon the commencement...
5 January 1990 T.I. (June 1990 Access Letter, ¶1285)
It is not necessary for the corporation to provide services in respect of the property which is rented, leased or sold. Discussion of the...
Articles
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report
Most commonly-used lease securitization structure: drop-down to LP (pp. 12:4)
In the most commonly used lease securitization structure in the last...
Subsection 1100(17)
Cases
Evans v. The Queen, 87 DTC 5226, [1987] 1 CTC 316 (FCTD)
The taxpayer acquired a motorhome in 1980 with the intention of renting it out in 1981 as a business endeavour. The leasing property restriction...
See Also
Agence du revenu du Québec v. J.D. Irving Limited, 2022 QCCA 241
The taxpayer (“JDI”) and another pulp and paper company in the Irving group (“IPPL”) engaged in several transactions to effectively...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | agency relationship respected so as to permit owner to charge for services performed by user | 281 |
J.D. Irving Limited v. Agence du revenu du Québec, 2020 QCCQ 2423, aff'd 2022 QCCA 241
The taxpayer ("JDI") and another pulp and paper company in the Irving group (“IPPL”) participated in transactions to effectively transfer...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | Stubart recognized that business operations can be carried on by an affiliated agent | 231 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | loss consolidation transaction entailing circular transfers of depreciable property confirmed | 90 |
Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)
A British corporation ("WBDL") entered into a distribution agreement with a California corporation ("WBI") pursuant to which WBI was granted the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | 136 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | 240 | |
| Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1) | main purpose was to make a profit, not take deduction | 264 |
General Motors Acceptance Corp. (U.K.) Ltd. v. I.R.C., [1985] BTC 324 (HC), aff'd [1987] BTC 71 (C.A.)
In the ordinary course of trade of a finance subsidiary ("GMAC"), it provided a financial package to car dealers, which entailed (1) GMAC...
Canadian Acceptance Corp. Ltd. v. Regent Park Butcher Shop Ltd. (1969), 67 WWR 297 (Man. C.A.)
Dickson J.A. found that the hiring of a cash register was a chattel lease notwithstanding a clause that provided that the lease was irrevocable...
Crawford v. Kingston, [1952] OR 715 (C.A.)
In finding that an agreement pursuant to which the plaintiff transferred 14 cows to his brother-in-law who was required to return the same number...
Administrative Policy
8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping
In finding that a campground generally would not be subject to the rental property restriction rules, the Directorate stated:
[P]aragraph 7 of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 - Paragraph 17(c) | costs of developing a campground would generally be added to Class 17(c) | 98 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 | septic tanks are structures | 167 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 | swimming pool is a water storage tank | 98 |
14 September 1992, T.I. (Tax Window, No. 24, p. 15, ¶2217)
Leasing property can include application software. In any event, Regulation 110(17.2) extends the concepts of rent to include gross revenue...
IT-443 "Leasing Property - Capital Cost Allowance Restrictions"
Subsection 1100(17.2)
See Also
Oke v. The Queen, 2009 DTC 1366, 2009 TCC 386 (Informal Procedure), aff'd 2011 DTC 5010 [at 5553], 2010 FCA 350
The taxpayer (Mr. Oke), who leased a recreational vehicle to a company that was in the business of renting recreational vehicles to movie studios...
Subsection 1100(17.3)
See Also
Thibeault v. The Queen, 2015 TCC 271
The taxpayer leased a boat (his only leasing asset) to a company of which he was the sole shareholder and director for use by the company in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) | boats were not a source of income | 60 |
Subsection 1100(21) - Certified Films and Video Tapes
Articles
Mandell, Yip, "Tax Shelters in the 1990s", 1991 Conference Report, c.35.
Subsection 1100(24) - Specified Energy Property
Articles
Mandel, Yip, "Tax Shelters in the 1990s", 1991 Conference Report, c. 35: Discussion of introduction of specified energy property rules.
Subsection 1100(25)
Administrative Policy
17 January 2020 External T.I. 2017-0685341E5 - Tax Comparison of the FIT & Net Metering Programs
Under the Feed-in Tariff and microFIT programs (the “FIT/micro-FIT Programs”) administered by the Ontario Power Authority (the “OPA”), a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | a credit generated by a business under the Ontario Net Metering Program is only income when applied, and is offset by a deduction for the electricity consumed | 261 |
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | credits received under the Ontario Net Metering Program respecting electricity generated for personal consumption are not income | 210 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 | general Class 43.1 or 43.2 treatment of specified energy property rules to equipment used in the Ontario Feed-in Tariff program | 157 |
Subsection 1100(26)
Administrative Policy
15 September 1992 T.I. (Tax Window, No. 24, p. 9, ¶2179)
The expression "distribution or production" should be interpreted broadly and would include "transmission". Whether a corporation's principal...
Paragraph 1100(26)(b)
Administrative Policy
26 May 2023 External T.I. 2022-0946411E5 - Classification of an Intermunicipal Management Board
A municipality may acquire an interest in a Canadian renewable energy project through an (apparently Quebec) intermunicipal management board...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) | an intermunicipal management board is a corporation given similarity of governing provisions to CBCA | 185 |