Subsection 1106(1)
Cases
Canada v. Larsen, 99 DTC 5757 (FCA)
The taxpayer and his three siblings gave a lumber company the right to enter their land to remove timber during a five-month period for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | 81 |
Administrative Policy
20 October 2000 External T.I. 2000-0041725 - Film Tax Credit
Discussion as to whether a corporation would qualify where it has Class A voting non-participating shares owned by a Canadian citizen, and Class B...
Excluded Production
Administrative Policy
2013 Ruling 2013-0513991R3 - Reg 1106 and excluded production
The granting of the option to acquire the production by the production company (Prodco), a qualified corporation which will claim the Canadian...
2012 Ruling 2012-0463231R3 - Reg 1106 and excluded production
A sole-purpose production company (Prodco) grants to to Master Distributor the exclusive right to exhibit, distribute and license the exhibition...
Paragraph (a)
Subparagraph (a)(iii)
Administrative Policy
16 May 2005 Internal T.I. 2005-0119061I7 F - Montant d'aide-actions
Prod Co, a wholly owned subsidiary of M Co and a "qualified corporation," produces a Canadian film or video production ("CFVP") at a cost of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subpargraph 12(1)(x)(viii) | funding of film production company by shares rather than loan would not give rise to assistance | 181 |
| Tax Topics - Income Tax Act - Section 125.4 - Subsection 125.4(1) - Assistance - Paragraph (a) | conversion of loan that was taxable assistance into shares is not itself assistance] | 192 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation - Paragraph (a) | conversion of loan that was taxable assistance under s. 12(1)(x) into shares with lower FMV would not give rise to forgiven amount | 304 |
| Tax Topics - General Concepts - Ownership | transfer of the economic benefit of copyright entails transfer of its ownership | 149 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) | subscription for shares of sub at overvalue constitutes a contribution of capital, generating a s. 53(1)(c) basis bump | 80 |
Clause (a)(iii)(A)
Administrative Policy
23 November 2012 External T.I. 2012-0449101E5 F - Production exclue - CIPCMC
Three production companies, Prodco 1, Prodco 2 and Prodco 3 produced productions each qualifying as a Canadian film or video production ("CFVP")...
Paragraph (b)
Subparagraph (b)(i)
Administrative Policy
12 October 2010 Internal T.I. 2010-0355761I7 F - PCMC - Dépense courante ou en capital
Regarding the meaning of "news programming," CRA stated:
[A] production dealing with a current events topic is not necessarily a news program and...
| 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 | expenditure on Canadian film production can be current expense if it is only of short-term use | 255 |
Subparagraph (b)(iii)
Cases
Productions GFP (III) Inc. v. Canada (Attorney General), 2019 FC 1613
The appellant (“GFP”) requested a preliminary opinion from the Canadian Audio-Visual Certification Office (CAVCO) as to the eligibility for...
Canada (Attorney General) v. Zone3-XXXVI Inc., 2016 FCA 242
The Department of Canadian Heritage through the Canadian Audio-Visual Certification Office (“CAVCO”) gave the taxpayer (a leading Quebec...
Zone3-XXXVI Inc. v. Canada (Attorney General), 2016 FC 75, rev'd 2016 FCA 242
The Department of Canadian Heritage through the Canadian Audio-Visual Certification Office (“CAVCO”) gave the taxpayer (a leading Quebec...
Subsection 1106(2)
Administrative Policy
30 May 2007 External T.I. 2006-0218101E5 F - Interaction entre 125.4(1) et 256(1.2)c)
CRA noted that the expanded definition of control in s. 256(1.2)(c) does not apply for s. 256(5.1) purposes and, therefore, did not apply for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(c) | s. 256(1.2)(c) does not affect the determination of de facto control | 33 |
Subsection 1106(7)
Administrative Policy
20 July 1998 External T.I. 9812515 - FILM TAX CREDIT-
The "term" 'treaty co-production twinning arrangement' means the pairing of two distinct film or video productions, one of which is a Canadian...
Subsection 1106(12)
Administrative Policy
16 November 2001 Internal T.I. 2001-0097587 F - COPRODUCTION-DROIT D'AUTEUR
The Directorate referred to an earlier ruling on a treaty co-production where the U.K., and qualified corporation, co-producers each held a master...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | licence to UK co-producer of rights, as copyright co-owner, to exploit its co-ownership rights outside Canada but with the licence back of those rights by the UK partnership licensee of the UK co-producer, did not constitute a copyright disposition | 249 |