Regulation 5202

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

Flexible application of formula

1.22 ... Where a corporation can readily obtain information that is reasonably similar to that required by section...

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Adjusted Business Income

See Also

Irving Oil Ltd. v. The Queen, 2000 DTC 2164 (TCC)

In finding that refund interest received by the taxpayer following a successful appeal of a substantial assessment represented business income...

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Administrative Policy

S4-F15-C1 - Manufacturing and Processing

Partnership look-through

1.23 ... The definition includes the corporation's share of active business income from a partnership but does not...

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11 April 1995 Internal T.I. 9429497 - ADJUBI - INTEREST INCOME

Interest earned on overpayments of taxes are not income from an active business.

Cost of capital

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

Exclusion of double counting

1.32 A double counting problem occurs in a group of associated corporations where one corporation in the group...

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Normally

Rental Cost

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

Royalties included

1.30 Royalty payments are considered to qualify as rental costs under paragraph (b) of the definition of cost of capital in...

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Cost of Labour

See Also

NRB Inc. v. The Queen, 93 DTC 295, [1993] 1 CTC 2435 (TCC)

The taxpayer, which used employees throughout the year to manufacture and erect modular buildings, was able to treat amounts paid to...

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Administrative Policy

S4-F15-C1 - Manufacturing and Processing

1.25 ... The simplest method generally will be an analysis of the T4 slips. ... This will also be acceptable for many corporations whose tax years...

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Words and Phrases
normally

Paragraph (a)

Administrative Policy

30 January 2004 Internal T.I. 2003-0037191I7 F - Fabrication /sous-traitants/frais de gestion

Individuals (the "Persons") performed services only for Cco but (for administrative ease) were paid by a sister of Cco (Bco), so that Bco was...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) s. 153(1) applicable to salaries paid as agent 143
Tax Topics - Income Tax Regulations - Regulation 5202 - Cost of Labour - Paragraph (b) - Subparagraph (b)(iii) tasks performed by subcontractors were not normally performed by employees 106
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose partial disallowance of salaries of taxpayer where it was not fully reimbursed by the recipient of their services 111

Paragraph (b)

Subparagraph (b)(iii)

Administrative Policy

30 January 2004 Internal T.I. 2003-0037191I7 F - Fabrication /sous-traitants/frais de gestion

Subcontractors doing business with Cco (a manufacturer) were paid on a piecework basis for inputs produced by them under production schedules set...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 5202 - Cost of Labour - Paragraph (a) cost of labour included amounts paid to a sister company that paid the employees on behalf of the manufacturer 205
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) s. 153(1) applicable to salaries paid as agent 143
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose partial disallowance of salaries of taxpayer where it was not fully reimbursed by the recipient of their services 111

Cost of Manufacturing and Processing Capital

See Also

D.MNR for Customs and Excise v. Amoco Canada Petroleum Co. Ltd., 86 DTC 6008, [1986] 1 CTC 124 (FCA)

The word "directly" in s. 1(a) of Part XIII of Schedule III to the Excise Tax Act was found to have a broad meaning of "without any intervening...

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Words and Phrases
directly
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Ordinary Meaning 27

Cost of Manufacturing and Processing Labour

Administrative Policy

19 December 2008 External T.I. 2008-0299321E5 F - Exploitation forestière et DBFT

Corporation B, in managing a lumberyard owned by Corporation A, grades and cuts logs and arranges for the sale or chipping of the log residues. ...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits managing processing operation of another corp. did not qualify 97

9 October 1990 Memorandum (Tax Window, Prelim. No. 1, p. 23, ¶1030)

Where the cost of foreign-based engineering designs of products and production facilities is included in amounts charged to a Canadian corporation...

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Qualified Activities

Cases

St. Catharines Standard Ltd. v. The Queen, 78 DTC 6168, [1978] CTC 258 (FCTD)

The receiving and storing of news by reporters at a newspaper, the researching and writing of articles or the preparation of advertisements, and...

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See Also

Lomex Inc. v. MNR, 92 DTC 2253, [1992] 2 CTC 2678, [1992] 1 CTC 2731 (TCC)

An operation of transporting animal residues (e.g., bones, meatscraps, feathers, blood and offal) by specially-adapted trucks to the taxpayer's...

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Words and Phrases
directly

Administrative Policy

S4-F15-C1 - Manufacturing and Processing

Line supervision: up to plant manager

1.35 The terms line supervision (a qualified activity) and administration (a non-qualified activity) may be...

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November 1991 Memorandum (Tax Window, No. 13, p. 13, ¶1578)

Minerals extracted from a mineral resource which have not been subsequently manufactured or processed do not constitute finished goods.

91 CPTJ - Q.30

Oil and gas which has been extracted and which is not yet been subsequently manufactured or processed does not constitute finished goods.

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