Regulation 1106

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...

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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...

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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...

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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...

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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...

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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")...

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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...

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Words and Phrases
news programming
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...

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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...

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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...

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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...

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Other locations for this summary
Tax Topics
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...

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