Regulation 1102

Subsection 1102(1)

Paragraph 1102(1)(a)

Administrative Policy

92 CPTJ - Q.13

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Paragraph 1102(1)(b)

Cases

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property characterization of depreciable property or inventory done on annual basis 355
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a) change in use on depreciable property conversion to inventory 120
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) applied to conversion of depreciable property into inventory 120
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment 355

See Also

Sivasubramaniam v. The Queen, 2008 DTC 3886, 2008 TCC 261 (Informal Procedure)

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Administrative Policy

20 July 2000 Internal T.I. 2000-0035017 - Conversion Capital Property to Inventory

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Paragraph 1102(1)(c)

Cases

Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Interprovincial Co-operative Ltd. v. The Queen, 87 DTC 5115, [1987] 1 CTC 222 (FCTD)

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Roywood Investments Ltd. v. The Queen, 79 DTC 5451, [1980] CTC 19 (FCTD), aff'd 81 DTC 5148, [1981] CTC 206 (FCA)

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Bureau et Bureau Inc. v. The Queen, 78 DTC 6562, [1978] CTC 695 (FCTD)

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Ben’s Ltd. v. MNR, 55 DTC 1152 (Ex Ct)

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See Also

568864 B.C. Ltd. v. The Queen, 2014 TCC 373

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership beneficial ownership in patents 414
Tax Topics - Income Tax Act - Section 79.1 - Subsection 79.1(2) beneficial ownership in patents 414

Garber v. The Queen, 2014 DTC 1045 [at 2812], 2014 TCC 1

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Jolly Farmer Products Inc. v. The Queen, 2008 DTC 4396, 2008 TCC 409

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Sivasubramaniam v. The Queen, 2008 DTC 3886, 2008 TCC 261 (Informal Procedure)

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Sherman v. The Queen, 2008 DTC 3069, 2008 TCC 186, aff'd 2009 DTC 5681, 2009 FCA 9

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Brown v. The Queen, 2001 DTC 1094 (TCC), aff'd supra 2003 DTC 5298 (FCA)

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Gascho Farms Ltd. v. The Queen, 97 DTC 808 (TCC)

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Malatest v. The Queen, 94 DTC 1779 (TCC), briefly aff'd 96 DTC 6377 (FCA)

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Moldaver v. MNR, 92 DTC 1564 (TCC)

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Administrative Policy

13 July 2012 External T.I. 2012-0443281E5 F - DPA- véhicule dans le cadre d'un bien locatif

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22 March 2012 External T.I. 2011-0425571E5 F - Avantage imposable - maison habitée sans frais

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23 January 2012 External T.I. 2011-0409671E5 F - Propriété superficiaire

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (e) land leased to corporation for business use not part of principal residence 152
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) benefit if building constructed at corporation’s expense for business purposes becomes shareholder’s property by accession 148
Tax Topics - General Concepts - Ownership whether tenant had Quebec right of superficies to garage erected by it determined whether it was its property 89
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property building erected by corporation on shareholder’s land not depreciable property unless shareholder renounces right of accession 213

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

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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 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Use of a Partner's Assets by a Partnership"

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Income Tax Regulation News, Release No. 3, 30 January 1995, under "Loss Utilization within a Corporate Group"

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Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films C.C.A.")

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21 November 1990 Memorandum (Tax Window, Prelim. No. 2, p. 8, ¶1074)

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81 CR - Q.23

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Paragraph 1102(1)(e)

See Also

Roger Dubois Inc. v. The Queen, 2014 DTC 1094 [3167], 2013 TCC 409, briefly aff'd 2015 CAF 235

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Words and Phrases
antique object
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions "deems" has several meanings 104
Tax Topics - Statutory Interpretation - Noscitur a Sociis no implied similarity requirement 140

Administrative Policy

18 June 2015 External T.I. 2015-0580391E5 F - Achat et location d'oeuvres d'art

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12 October 1994 External T.I. 5-942004 -

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Regulation 1102(2)

Administrative Policy

7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2016-0651711C6 F - RRIF, Transfer of designated benefit

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Words and Phrases
land
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Personal-Use Property land underlying duplex used 40% personally is not personal-use property 214
Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(iii) capital loss recognition on land underlying duplex used 40% personally 71
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(6.11) computation of eligible amount following year of death 285

Subsection 1102(4) - Improvements or Alterations to Leased Properties

Administrative Policy

IT-464R "Capital Cost Allowance - Leasehold Interests"

Subsection 1102(5) - Buildings on Leased Properties

Administrative Policy

7 August 2014 External T.I. 2014-0528841E5 F - Changement à une résidence principale

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) addition of a door to an exterior wall could be considered a structural change triggering a change of use 128
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) taxable benefit if renovations paid for by tenant-corporation increase the FMV of property to owner-shareholder 90

2015 Ruling 2014-0552291R3 - Paragraph 1102(5)(a) of the Regulations

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17 August 1994 External T.I. 5-941523 -

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Revenue Canada Round Table CTF-1992 Conference, Q. 70 No. 922851 (Not Included in Final Report)

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IT-464R "Capital Cost Allowance - Leasehold Interests"

Subsection 1102(14) - Property Acquired by Transfer, Amalgamation or Winding-Up

Cases

Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Administrative Policy

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a) property remaining idle after deemed acquisition as depreciable property not a change of use 166
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) deemed depreciable property in fact not used for income-producing purpose 183

S4-F7-C1 - Amalgamations of Canadian Corporations

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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 58
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 103
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 155
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 126
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 145
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 97
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 82
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 164
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) realted party, majority and 50% group exceptions 448
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 103
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 104
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 159
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 81
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 60
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 114
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 47
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 260
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 0
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 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 135
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 133
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 159
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 38
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 328
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 181
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 247
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 171
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 218
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 106
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 56
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 123
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 415
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 323
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 96

10 April 1997 T.I. 970422

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90 C.R. - Q38

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Subsection 1102(23)

Administrative Policy

13 March 2017 External T.I. 2016-0626641E5 F - Election - Subsection 1101(5b.1) Reg.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(5b.1) only one Reg. 1101(5b.1) election is required where work on an addition to a non-residential building extends over more than one year 329

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