Regulation 402

Subsection 402(3)

See Also

International Harvester Co. of Canada, Ltd. v. Provincial Tax Commission, [1949] A.C. 36 (PC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) apportionment between manufacturing and selling 82

Commissioners of Taxation v. Kirk, [1900] A.C. 588 (PC)

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Words and Phrases
derived

Administrative Policy

1 September 2015 Internal T.I. 2013-0507381I7 - Transfer pricing adjustments and gross revenue

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) [s. 247(2) increases to gross revenues] 37
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Gross Revenue sales (but not purchases) transfer pricing adjustments to gross revenue 39

31 March 2014 Internal T.I. 2013-0514921I7 - Meaning of "gross revenue" follow-up

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Gross Revenue cost reductions not included 240

19 February 2014 Internal T.I. 2013-0508121I7 - Provincial Income Allocation among Joint Venturers

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11 March 2014 Internal T.I. 2013-0506801I7 - Salary and Wages, Part IV of the Regulations

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19 November 2013 External T.I. 2012-0455731E5 F - Interprovincial income allocation

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21 March 1996 Memorandum 960592 (C.T.O. "Interest on Overpayment and Adjusted Business Income")

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19 May 1994 External T.I. 5-940551 -

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15 February 1994 Internal T.I. 7-933546 -

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16 March 1993 T.I. (Tax Window, No. 30, p. 21, ¶2505)

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2 February 1993 Memorandum (Tax Window, No. 28, p. 13, ¶2417)

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Paragraph 402(3)(a)

Subparagraph 402(3)(a)(i)

Administrative Policy

16 January 2017 Internal T.I. 2016-0651411I7 - Reassessment period – transfer pricing

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) s. 152(4)(b)(iii) permits a reallocation of taxable income among provinces where a taxpayer’s sales revenue has been increased under s. 247(2) 337

Subsection 402(4)

See Also

Westar Mining Ltd.v. The Queen, 92 DTC 6358 (FCA)

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Words and Phrases
derived

MNR v. Hollinger North Shore Exploration Co., 63 DTC 1031 (SCC)

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Words and Phrases
derived

Administrative Policy

15 March 1999 T.I. 982941

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26 March 1997 T.I. 963064

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30 March 1995 Internal T.I. 7-950610 -

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94 C.P.T.J. - Q. 7

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Paragraph 402(4)(b)

Administrative Policy

20 September 2012 External T.I. 2011-0430811E5 F - Attribution à un établissement stable

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(4) - Paragraph 402(4)(c) - Subparagraph 402(4)(c)(ii) application of Reg. 404(4)(c)(ii) to ore processed in two provinces 196

Paragraph 402(4)(c)

Subparagraph 402(4)(c)(ii)

Administrative Policy

20 September 2012 External T.I. 2011-0430811E5 F - Attribution à un établissement stable

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(4) - Paragraph 402(4)(b) as Reg. 404(4)(c)(ii) prevailed over Reg. 404(4)(b) re ore processed in two provinces, its application would not be affected by the negotiation of the export sales by personnel in the 2nd province 105

Subsection 402(4.1)

Administrative Policy

31 January 2013 Internal T.I. 2012-0470361I7 - PIA - Non-manufactured goods (ITR 402(4.1))

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Subsection 402(5)

Administrative Policy

October 1989 Revenue Canada Round Table - Q.26 (Jan. 90 Access Letter, ¶1075)

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Subsection 402(6)

See Also

Les Développements Iberville Ltée v. Agence du Revenu du Québec, 2018 QCCA 1886 (Quebec Court of Appeal)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) abuse to use rollover provisions to avoid rather than defer tax 633
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) abuse of Quebec equivalents of ss. 85(1) and 97(2) to avoid (rather than defer) tax 390
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate property bifurcated between capital and income portion on acquisition 94
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense improvements to leased retail premises were not demonstrated to be made only at tenants’ requests 91
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(1) no policy of permitting differing Quebec and federal year ends 185

Administrative Policy

2 February 2018 Internal T.I. 2017-0728331I7 - Central paymaster - partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 402.1 - Subsection 402.1(5) application of the paymaster rules to salaries paid by a partnership 234

7 August 2013 External T.I. 2012-0460511E5 - Reg 402(6) and SIFT Partnerships

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20 October 2000 External T.I. 2000-0048685 - Allocation Taxable Income Between Provinces

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Subsection 402(7)

Cases

W.E. Roth Construction Ltd. v. Minister of Finance (2001), 141 OAC 366 (CA)

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See Also

W.E. Roth Construction Ltd. v. Minister of Finance (Ontario), 99 DTC 5791 (Ont. Sup. Ct. J.)

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Administrative Policy

S4-F15-C1 - Manufacturing and Processing

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Words and Phrases
normally

25 September 2013 External T.I. 2013-0477571E5 F - Partnership - fin. fees and mng fees

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23 October 1991 T.I. (Tax Window, No. 12, p. 22, ¶1550)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 409 23

Subsection 402(8)

See Also

Enterprise Foundry (N.B.) Ltd. v. MNR, 64 DTC 660 (TAB)

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Words and Phrases
commission
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(2) employee with general authority to contract based on authorized prices and with authority over inventory in independent warehouse was PE 275

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