Schedule II

Table of Contents

Class 1

Cases

The Queen v. Hampton Golf Club Ltd., 86 DTC 6513, [1986] 2 CTC 403 (FCTD)

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See Also

Repsol Canada Ltd. v. The Queen, 2015 TCC 21, aff'd 2017 FCA 193

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Words and Phrases
distribution processing

Lansdowne Equity Ventures Ltd. v. The Queen, 2007 DTC 3, 2006 TCC 565

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Swan Lake Recreation Resort Ltd. v. Registrant, Kamloops Land Title Office (1999), 174 DLR (4th) 549 (BCSC)

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Administrative Policy

8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping

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Words and Phrases
structure
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of developing a campground would generally be added to Class 17(c) 98
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) campground, if a business, not subject to leasing property restriction rule 108
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 swimming pool is a water storage tank 98

Paragraph 1(n)

Cases

Canada v. Repsol Energy Canada Ltd., 2017 FCA 193

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Paragraph 1(q)

Cases

The Queen v. Hampton Golf Club Ltd., 86 DTC 6513, [1986] 2 CTC 403 (FCTD)

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Words and Phrases
structure

British Columbia Forest Products Ltd. v. MNR, 71 DTC 5178, [1971] CTC 270 (SCC)

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Words and Phrases
structure building

See Also

Agence du revenu du Québec c. Adélard Soucy (1975) Inc., 2021 QCCA 1050

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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 a movable structure for warming a soldering operation was not described in Class 8 437

Lloyd v. The Queen, 2002 DTC 1493 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date taxpayer can attack own transaction as legally ineffective 138
Tax Topics - General Concepts - Tax Avoidance taxapyer can argue legally ineffective transactions 139
Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) 76

Sun Life Assurance Co. of Canada v. The Queen, 97 DTC 422 (TCC)

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Words and Phrases
land building
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A density rights are land even if building constructed 87

Cadillac Fairview Corp. Ltd. v. The Queen, 97 DTC 405, [1996] 2 CTC 2197 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A costs of density rights were land costs 212

Superior Pre-Knit Septic Tanks Ltd. v. The Queen, 78 DTC 6263, [1978] CTC 431 (SCC)

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Administrative Policy

16 March 2012 External T.I. 2012-0432101E5 F - Acquisition d'un séparateur d'huile

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17 December 2014 External T.I. 2014-0560281E5 - Arena and skateboard park - CCA classes

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IT-79R3 "Capital Cost Allowance - Buildings or other Structures"

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Words and Phrases
building structure

Class 2

Cases

Gulf Canada Resources Ltd. v. The Queen, 95 DTC 5189, [1995] 1 CTC 334 (FCTD), partially rev'd 96 DTC 6065 (FCA).

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Pacific Northern Gas Ltd. v. The Queen, 90 DTC 6252, [1990] 1 CTC 380 (FCTD), aff'd 91 DTC 5287 (FCA)

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Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)

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Alberta Oil Sands Pipeline Ltd. v. The Queen, 88 DTC 6059, [1988] 1 CTC 99 (FCTD)

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Northern and Central Gas Corp. Ltd. v. The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA)

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Class 3

See Also

MNR v. Plastibeton Inc., 86 DTC 6400, [1986] 2 CTC 211 (FCA)

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Plan A Leasing Ltd. v. The Queen, 76 DTC 6159, [1976] CTC 261 (FCTD)

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Administrative Policy

28 April 2004 External T.I. 2004-0064781E5 - Classification of Conduit

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Class 4

Administrative Policy

16 November 2009 External T.I. 2009-0313081E5 F - Classification d'un chemin de fer avant 1958

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Words and Phrases
common carrier

Class 6

Administrative Policy

18 December 2013 External T.I. 2013-0479421E5 F - Section 30 and Cranberry Farm

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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 initial cranberry plant planting is a cost of land 94
Tax Topics - Income Tax Act - Section 30 costs of clearing, levelling and draining lands, but not of constructing basins, for a cranberry farm are currently deductible 136
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of constructing cranberry farm basins included in Class 17 79
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 irrigation system included, drainage costs deductible under s. 30 79

8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping

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Words and Phrases
water storage tank
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of developing a campground would generally be added to Class 17(c) 98
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) campground, if a business, not subject to leasing property restriction rule 108
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 septic tanks are structures 167

Paragraph (e)

Administrative Policy

17 July 2007 External T.I. 2007-0220121E5 F - Lac artificiel - catégorie d'amortissement

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Words and Phrases
water storage tank

Class 7

Administrative Policy

12 March 2012 Internal T.I. 2011-0431631I7 F - Catégorie d'amortissement- maison flottante

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Vessel vessel is as defined in Canada Shipping Act, 2001 115
Tax Topics - Statutory Interpretation - Interpretation Act - Section 44 - Paragraph 44(h) IA s. 44(h) applied to reference definition in replacement Canada Shipping Act 48

Paragraph 7(c)

Administrative Policy

25 November 2010 External T.I. 2010-0377841E5 F - Catégorie d'amortissement - bateau

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 44 - Paragraph 44(h) “vessel” informed by meaning in replacement Canada Shipping Act 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Vessel "vessel" now defined in (replacement) Canada Shipping Act, 2001 55

Class 8

Cases

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. The Queen, 92 DTC 6452, [1992] 2 CTC 363 (FCTD)

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Pacific Northern Gas Ltd. v. The Queen, 90 DTC 6252, [1990] 1 CTC 380 (FCTD), aff'd 91 DTC 5287 (FCA)

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Nowsco Well Service Ltd. v. The Queen, 88 DTC 6300, [1988] 2 CTC 24 (FCTD)

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Alberta Oil Sands Pipeline Ltd. v. The Queen, 88 DTC 6059, [1988] 1 CTC 99 (FCTD)

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Northern and Central Gas Corp. Ltd. v. The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA)

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Nova Construction Co. Ltd. v. The Queen, 83 DTC 5105, [1983] CTC 58 (FCTD)

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Butler v. MNR, 67 DTC 5019, [1967] CTC 7 (Ex Ct)

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Southam Business Publications Ltd. v. MNR, 66 DTC 5215, [1966] CTC 265 (Ex. Ct.), briefly aff'd 67 DTC 5150 (SCC)

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See Also

Agence du revenu du Québec c. Adélard Soucy (1975) Inc., 2021 QCCA 1050

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 - Paragraph 1(q) a movable structure for warming M&P equipment was a Class 1(q) building 369

Roy Legumex Inc. v. MNR, 90 DTC 1858, [1990] 2 CTC 2389 (TCC)

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Re St. Lawrence Cement Inc. (1985), 52 OR (2d) 545 (HCJ.)

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Administrative Policy

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 556
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 791
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 218
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 275
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 254
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 222
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 155
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 212
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 351
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 70
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 166
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 207
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 65
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 230
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 65
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 152
Tax Topics - Income Tax Act - Section 68 197
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 75
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 212
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 431
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 75
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 152
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 229
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 321
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 317
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 221

12 June 2014 External T.I. 2014-0527651E5 - Whether keeping a zoo is a farming activity

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming zoo not farming 122

18 December 2013 External T.I. 2013-0479421E5 F - Section 30 and Cranberry Farm

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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 initial cranberry plant planting is a cost of land 94
Tax Topics - Income Tax Act - Section 30 costs of clearing, levelling and draining lands, but not of constructing basins, for a cranberry farm are currently deductible 136
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of constructing cranberry farm basins included in Class 17 79
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 costs of constructing irrigation pond included 33

20 March 2013 External T.I. 2012-0442571E5 F - Coût d'acquisition d'un terrain

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base cost of land acquired from developer equal to total barter value minus amounts allocated to Classes 8 and 17 152

7 August 2007 Internal T.I. 2007-0240691I7 - Music CD production-CCA class

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13 December 1994 External T.I. 9416075 - RAPID TRANSIT CAR

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4 August 1992 T.I. 921654 (April 1993 Access Letter, p. 132, ¶C9-259)

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9 April 1992 Memorandum (Tax Window, No. 18, p. 15, ¶1870)

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11 October 1991 T.I. (Tax Window, No. 11, p. 4, ¶1520)

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7 October 1991 T.I. (Tax Window, No. 10, p. 19, ¶1501)

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IT-79R3 "Capital Cost Allowance - Buildings or other Structures"

Paragraph 8(a)

See Also

Adélard Soucy (1975) Inc. v. Agence du revenu du Québec, 2019 QCCQ 6956, rev'd 2021 QCCA 1050

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 building was functionally integrated with M&P so as to itself be M&P equipment 210

Québec (Sous-ministre du Revenu) v. Plastiques Simport ltée, 2007 QCCA 160

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Paragrpah 8(i)

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22 March 2011 Internal T.I. 2010-0387551I7 F - Dépenses - travailleur indépendant

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Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h) expenses of costumes, breast implants and rejuvenation expenses of erotic website were non-deductible 165

Paragraph 8(j)

See Also

Agence du revenu du Québec v. Unidisc Musique Inc., 2021 QCCA 393

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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 master recordings were intangible (Class 14.1) rather than tangible (Class 8) property 341
Tax Topics - General Concepts - Onus failure to lead evidence as to allocation meant that the taxpayer was stuck with the ARQ allocation 143
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) misunderstanding by the ARQ of the Copyright provisions supporting its reassessment did not invalidate it 152

Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818, rev'd 2021 QCCA 393

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Words and Phrases
intangible property
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14.1 master recordings are tangible rather than intangible property 308

Class 9

Administrative Policy

11 March 2016 External T.I. 2016-0633111E5 - CCA Class of a drone

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Words and Phrases
aircraft

Class 10

Cases

Lindwest Holdings Ltd. v. The Queen, 88 DTC 6482, [1988] 2 CTC 287 (FCTD)

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Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)

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Nowsco Well Service Ltd. v. The Queen, 88 DTC 6300, [1988] 2 CTC 24 (FCTD)

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The Queen v. Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD)

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Halliburton Services Ltd. v. The Queen, 85 DTC 5336, [1985] 2 CTC 52 (FCTD), aff'd 90 DTC 6320 (FCA).

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Howden Brothers Construction Ltd. v. The Queen, 80 DTC 6393, [1980] CTC 529 (FCTD)

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See Also

Suncor Energy Inc. v. The Queen, 2001 DTC 660 (TCC), aff'd 2002 DTC 7395, 2002 FCA 350

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Words and Phrases
structure

Cargill Ltd. v. The Queen, 96 DTC 1461 (TCC)

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Gordon v. The Queen, 95 DTC 493 (TCC)

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8 January 1996 External T.I. 9530675 - CLASSIFICATION OF A MOTORHOME

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31 January 1994 Internal T.I. 9328977 - CCA CLASS OF BUILDING USED IN PEAT PROCESSING

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24 March 1993 Memorandum (Tax Window, No. 32, p. 20, ¶2623)

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10 November 1992 Memorandum 923297 (September 1993 Access Letter, p. 409, ¶20-1159)

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2 December 1992 Memorandum (Tax Window, No. 27, p. 22, ¶2323)

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13 January 1992 T.I. (Tax Window, No. 15, p. 9, ¶1693)

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11 October 1991 T.I. (Tax Window, No. 11, p. 4, ¶1520)

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Paragraph 10(x)

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17 February 2010 Internal T.I. 2009-0348461I7 F - Transfert d'une PCMC à une société mère

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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 - Current expense vs. capital acquisition fully claimed films productions acquired from production sub on capital account 66

Class 12

Cases

Howden Brothers Construction Ltd. v. The Queen, 80 DTC 6393, [1980] CTC 529 (FCTD)

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See Also

Desgagné v. The Queen, 2012 DTC 1237 [at 3664], 2012 TCC 63 (Informal Procedure)

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McKee v. The Queen, 77 DTC 5345, [1977] CTC 491 (FCTD)

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29 October 2013 External T.I. 2013-0507121E5 - Website costs

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24 November 2010 External T.I. 2010-0380521E5 - Web page costs

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26 April 1995 Internal T.I. 9506797 - CCA - BOOKPLATE COSTS

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13 April 1994 Internal T.I. 9400887 - COMPUTER SOFTWARE

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23 November 1992 T.I. 923452 (September 1993 Access Letter, p. 409, ¶C20-075)

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7 September 1992 T.I. (Tax Window, No. 24, p. 7, ¶2189)

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20 August 1992 T.I. (Tax Window, No. 23, p. 14, ¶2170)

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4 August 1992 T.I. 921654 (April 1993 Access Letter, p. 132, ¶C9-259)

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4 March 1992 T.I. (Tax Window, No. 17, p. 21, ¶1782)

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9 April 1992 Memorandum (Tax Window, No. 18, p. 15, ¶1870)

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3 January 1992 T.I. (Tax Window, No. 15, p. 17, ¶1681)

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25 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1088)

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18 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1087)

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Paragraph (c)

Administrative Policy

18 May 2011 External T.I. 2011-0392441E5 F - Outils - déduction pour amortissement

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) CCA claim was to be proportionately reduced based on personal use percentage 64

Class 13

Cases

The Queen v. Mount Robson Motor Inn Ltd., 81 DTC 5188, [1981] CTC 345 (FCA)

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The Queen v. Saskatoon Drug & Stationery Co. Ltd., 78 DTC 6396, [1978] CTC 578 (FCTD)

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See Also

Plan A Leasing Ltd. v. The Queen, 76 DTC 6159, [1976] CTC 261 (FCTD)

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Rudnikoff v. The Queen, 75 DTC 5008, [1975] CTC 1 (FCA)

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Administrative Policy

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

Class 14

Cases

Bomag (Canada) Ltd. v. The Queen, 81 DTC 5085, [1981] CTC 156 (FCTD), aff'd 84 DTC 6363, [1984] CTC 378 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 51
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost of obtaining surrender of previous contact was part of cost of new contract 36

MNR v. Canadian Glassine Co. Ltd., 76 DTC 6083, [1976] CTC 141 (FCA)

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Words and Phrases
franchise

Capital Management Ltd. v. MNR, 68 DTC 5041 (SCC)

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Metropolitan Taxi Ltd. v. MNR, 67 DTC 5073 (Ex Ct), aff'd 68 DTC 5098, [1968] CTC 163 (SCC)

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Investors Group v. MNR, 65 DTC 5120, [1965] CTC 192 (Ex Ct)

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Mandrell Industries, Inc. v. M.N.R., 65 DTC 5142 (Ex Ct)

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MNR v. Kirby Maurice Co. Ltd., 58 DTC 1033, [1958] CTC 41 (Ex Ct)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) purchaser exercising no independent judgment 148

Golden Arrow Sprayers Ltd. v. MNR, 61 DTC 1185 (Ex Ct)

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See Also

Rocheleau v. The Queen, 2010 DTC 1016 [at 2615], 2009 TCC 484 (Informal Procedure)

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Gouchee v. MNR, 67 DTC 203 (TAB)

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No. 728 v. MNR, 61 DTC 34 (TAB)

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No. 678 v. MNR, 60 DTC 45 (TAB)

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Administrative Policy

7 November 2011 Internal T.I. 2011-0424641I7 F - Right to cut Christmas trees

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Timber Resource Property right to cut Christmas trees was not a timber resource property 93
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(e) Christmas trees are not “timber” 184

17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) - Paragraph 1219(1)(h) completing an exploratory geothermal well ultimately used in production generates Class 43.1 costs, not CRCE 264
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(viii) inclusion of cost of completing geothermal exploratory wells in fact used in production 92

30 July 2015 External T.I. 2014-0552041E5 F - Permis XXXXXXXXXX

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure renewable government licences were ECP, not Class 14 49

30 May 2013 External T.I. 2013-0487301E5 - 3P Project

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25 January 2007 External T.I. 2006-0199451E5 - License Agreement

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2007 Ruling 2006-0218781R3 - XXXXXXXXXX

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16 November 1994 Internal T.I. 9414677 - FILM RIGHTS

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9 November 1994 Internal T.I. 9425187 - PLANT BREEDERS RIGHTS ACT

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7 September 1992 T.I. (Tax Window, No. 24, p. 7, ¶2189)

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20 August 1992 T.I. (Tax Window, No. 23, p. 14, ¶2170)

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14 May 1990 T.I. AC59728 [bare right to income not a concession]

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IT-283R2 "Capital Cost Allowance - Video Tapes, Videotapes Cassettes, Films, Computer Software and Master Recording Media"

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IT-477 "Capital Cost Allowance - Patents, Franchises, Concessions and Licences," consolidated October 2001

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Articles

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

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Scheuermann, "Income and Commodity Tax Aspects of Acquiring and Exploiting Technology", 1991 Conference Report, c. 45.

Class 14.1

See Also

Agence du revenu du Québec v. Unidisc Musique Inc., 2021 QCCA 393

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(j) the portion of the value of master recordings that was tangible property was not demonstrated by the taxpayer 269
Tax Topics - General Concepts - Onus failure to lead evidence as to allocation meant that the taxpayer was stuck with the ARQ allocation 143
Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) misunderstanding by the ARQ of the Copyright provisions supporting its reassessment did not invalidate it 152

Perron-Ali v. The Queen, 2021 TCC 6 (Informal Procedure)

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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 - Know-How and Training costs of training on how to invest in real estate were capital expenditures 190

Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818, rev'd 2021 QCCA 393

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(j) purchase cost of master music recordings was for Class 8(j) tangible property 368

Administrative Policy

27 November 2018 CTF Roundtable Q. 15, 2018-0780011C6 - Class 14.1

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(35) - Paragraph 13(35)(a) capital expenditures not giving rise to property are deemed to be goodwill property 106

19 July 2018 External T.I. 2017-0727041E5 - Legal and accounting fees - aborted share purchase

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Paragraph (a)

See Also

Commissioner of State Revenue v Placer Dome Inc., [2018] HCA 59

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Words and Phrases
goodwill
Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Other discounted cash flow valuation undervalued resource lands and residual valuation overstated goodwill 342
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property protean nature of property concept 491

Class 16

Paragraph (e)

Administrative Policy

16 June 2010 External T.I. 2009-0344861E5 F - Actifs de la Catégorie 16

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Class 17

Cases

The Queen v. Mont-Sutton Inc., 99 DTC 5733, [1999] F.T.R. 33467 (FCA)

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Words and Phrases
surface construction

Administrative Policy

27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures

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18 December 2013 External T.I. 2013-0479421E5 F - Section 30 and Cranberry Farm

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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 initial cranberry plant planting is a cost of land 94
Tax Topics - Income Tax Act - Section 30 costs of clearing, levelling and draining lands, but not of constructing basins, for a cranberry farm are currently deductible 136
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 costs of constructing irrigation pond included 33
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 irrigation system included, drainage costs deductible under s. 30 79

8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping

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Words and Phrases
surface construction
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) campground, if a business, not subject to leasing property restriction rule 108
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 septic tanks are structures 167
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 swimming pool is a water storage tank 98

14 February 2005 External T.I. 2005-011130 -

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28 June 2001 External T.I. 2001-0068425 - CLEARING LAND-GOLF COURSE

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Class 22

Cases

Lindwest Holdings Ltd. v. The Queen, 88 DTC 6482, [1988] 2 CTC 287 (FCTD)

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The Queen v. Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD)

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Class 24

Administrative Policy

IT-336R "Pollution Control Property"

27 September 1991 T.I. (Tax Window, No. 10, p. 18, ¶1485)

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27 September 1991 Memorandum (Tax Window, No. 10, p. 18, ¶1487)

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Class 26

Administrative Policy

7 June 2017 CPTS Roundtable, 2017-0695131C6

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition Q.1 - Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis 213
Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Canadian Resource Property - Paragraph (d) Q.2 - a Canadian resource royalty interest requires a right to “take production” 135
Tax Topics - Treaties - Income Tax Conventions - Article 13 Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them 193
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) Q.4 - by analogy to mining, hydrocarbons may be similar properties 348
Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) Q.5 - normal course dispositions of oil and gas properties generally are not of a separate business 131
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) Q.5 - application of Scales test to determining whether there is a separate business 224
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 49 Q.8 - taxpayers generally have the documentary evidence on hand to allocate costs between pipelines and pipeline appendages 117

Class 28

Administrative Policy

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1570)

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Class 29

Cases

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)

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The Queen v. Donohue Normick Inc., 96 DTC 6061 (FCA)

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The Queen v. Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc., 94 DTC 6541, [1994] 2 CTC 336 (FCA)

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Halliburton Services Ltd. v. The Queen, 85 DTC 5336, [1985] 2 CTC 52 (FCTD), aff'd 90 DTC 6320 (FCA).

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Nova Construction Co. Ltd. v. The Queen, 83 DTC 5105, [1983] CTC 58 (FCTD)

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See Also

Adélard Soucy (1975) Inc. v. Agence du revenu du Québec, 2019 QCCQ 6956, rev'd 2021 QCCA 1050

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(a) a building for warming equipment qualified as “manufacturing or processing machinery or equipment” 333

Coop de travailleurs en serres Belle-de-Jour v. Agence du revenu du Québec, 2019 QCCQ 6609

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Words and Phrases
processing manufacturing
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) use of greenhouses to further grow flowers before use in making floral arrangements was separate from the taxpayer’s greenhouse plant-growing farming business 221
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming use of greenhouses to further grow flowers before use in making floral arrangements did not constitute farming 163

Stark International Inc. v. The Queen, 2019 TCC 248

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Words and Phrases
sale
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) a use test could be applied by looking beyond the property’s immediate intended use 235

Environnement Sanivac Inc. v. ARQ, 2016 QCCQ 9461

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Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) - Subparagraph (c)(i) transporting trucks with decanting tanks used in M&P 281

Mont-Sutton Inc. v. The Queen, 96 DTC 1472 (TCC)

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Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)

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Lehmann Bookbindings Ltd. v. MNR, 92 DTC 1308, [1992] 1 CTC 2766 (TCC)

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Roy Legumex Inc. v. MNR, 90 DTC 1858, [1990] 2 CTC 2389 (TCC)

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Red Deer Adviser Publications Ltd. v. MNR, 89 DTC 520, [1989] 2 CTC 2315 (TCC)

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Words and Phrases
same transaction

Administrative Policy

6 June 2019 CPTS Roundtable, 2019-0816111C6

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) taxpayers can choose between reasonable alternative formats (e.g. hard or soft) for providing their tax working papers/records 140
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) extension of M&P guidance to oil and gas sector 61
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management project expenses incurred after determining economic feasibility and before project approval are generally deductible 248
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures no acceptance that expenses incurred before decision to proceed are thereby on current account 186
Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Accelerated Canadian Development Expense - Paragraph (a) - Subparagraph (a)(ii) accelerated CDE deduction can be available for drilling on land acquired from an affiliate 131

7 March 2019 Internal T.I. 2018-0781511I7 F - Fabrication ou transformation

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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 commercial printing or photocopying operations may not be M&P 160

15 January 2015 External T.I. 2014-0548101E5 F - Sens de "fabrication ou transformation"

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Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing steel rod plating could qualify 151

S4-F15-C1 - Manufacturing and Processing

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11 August 2014 Internal T.I. 2014-0528231I7 F - Dépenses en immobilisation en RS&DE

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7 January 2014 External T.I. 2013-0515361E5 - CCA and Manufacturing or Processing of Malt

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19 November 2013 External T.I. 2013-0510351E5 - Steel Tanks and Oak Barrels of a Winery Business

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22 October 2013 External T.I. 2013-0503311E5 - Class. of steel tanks & oak barrel for CCA purpose

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3 April 2012 External T.I. 2011-0426341E5 F - Catégories 29 et 43

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4 June 2010 External T.I. 2010-0358811E5 F - Catégorie d'amortissement d'un moule

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22 January 2009 External T.I. 2008-0290971E5 F - Bénéfices de fabrication et de transformation

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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 operation of breaking bulk packages into smaller lots for repackaging and sale was not “processing” 166

21 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 23, ¶1005)

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Class 31

Cases

Vaillancourt v. The Queen, 86 DTC 6449, [1986] 2 CTC 188 (FCTD), rev'd 91 DTC 5352 (F.R.), 91 DTC 5408 (E.) (FCA)

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Johns-Manville Canada v. The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46

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Administrative Policy

86 C.R. - Q.25

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IT-304R "Capital Cost Allowance - Condominiums"

Class 32

Administrative Policy

IT-304R "Capital Cost Allowance - Condominiums"

Class 34

Administrative Policy

10 August 1994 External T.I. 9405135 - WIND TURBINES

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2 February 1994 Internal T.I. 9400307 - HYDRO ELECTRIC EQUIPMENT FOR A MINE

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Class 39

Cases

Will Kare Paving & Contracting Ltd. v. The Queen, 98 DTC 6203 (FCA)

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Words and Phrases
primarily

Class 41

Administrative Policy

November 1991 Memorandum (Tax Window, No. 12, p. 21, ¶1570)

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Class 43

See Also

Ateliers Ferroviaires de Mont-Joli Inc. v. The Queen, 2011 DTC 1358 [at 2006], 2011 TCC 352

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Scieri St-Elzéar Inc. v. The Queen, 2003 DTC 14 (TCC)

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Administrative Policy

4 June 2010 External T.I. 2009-0324801E5 F - catégorie 43

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16 September 2008 External T.I. 2008-0268021E5 F - Catégorie 43 - poinçon hydraulique

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Class 43.1

Administrative Policy

17 January 2020 External T.I. 2017-0685341E5 - Tax Comparison of the FIT & Net Metering Programs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit a credit generated by a business under the Ontario Net Metering Program is only income when applied, and is offset by a deduction for the electricity consumed 261
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit credits received under the Ontario Net Metering Program respecting electricity generated for personal consumption are not income 210
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(25) application of exception to the specified energy property rules to equipment used in the Ontario Feed-in Tariff program 364

16 May 2017 External T.I. 2016-0670661E5 - Capital Cost of De-icing Equipment

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Words and Phrases
related fixture

6 May 2014 Internal T.I. 2014-0521261I7 - Biomass Electrical Facility Owned by First Nation

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6 July 2012 External T.I. 2012-0444401E5 - Definition of “wood waste” in Class 43.2

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3 April 2013 External T.I. 2012-0469941E5 - CCA class and rate

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11 May 2009 External T.I. 2008-0276761E5 F - Class 43.1 and 43.2

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Articles

Tim Hay, "Federal Income Tax Incentives for Independent Power Generation: Accelerated Capital Cost Allowance of Class 43.1 Assets and 100% Write-Off of Canadian Renewable and Conservation Expenses", Business Vehicles, Vol, VII, No. 3, 2001, p. 342.

Paragraph (d)

Subparagraph (d)(vii)

Subparagraph (d)(viii)

Administrative Policy

17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1219 - Subsection 1219(1) - Paragraph 1219(1)(h) completing an exploratory geothermal well ultimately used in production generates Class 43.1 costs, not CRCE 264
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14 if renegotiation, further permit fees may generate Class 14 property 119

11 January 2011 External T.I. 2010-0385231E5 F - Class 43.2

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(xiii) digester producing gas from municipal sludge for thermal production could qualify 196

Subparagraph (d)(xiii)

Administrative Policy

11 January 2011 External T.I. 2010-0385231E5 F - Class 43.2

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(viii) biomass boiler using wood chips from poplars grown by taxpayer did not qualify 215

Class 43.2

Administrative Policy

S3-F8-C1 - Principal-business Corporations in the Resource Industries

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10 February 2015 External T.I. 2014-0549331E5 F - Borne de recharge – catégorie d'amortissement

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21 October 2014 External T.I. 2014-0543041E5 - Class 43.2 - Photovoltaic System

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21 August 2013 External T.I. 2013-0486441E5 - CCA and ITCs on anaerobic digester

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29 February 2012 External T.I. 2012-0435151E5 - Installation of Solar Panels

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Class 45

Administrative Policy

5 October 2007 APFF Roundtable Q. 26, 2007-0243381C6 F - Classification des équipements de bureautique

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Class 46

Administrative Policy

29 October 2013 External T.I. 2013-0507121E5 - Website costs

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Class 49

Administrative Policy

7 June 2017 CPTS Roundtable, 2017-0695131C6

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition Q.1 - Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis 213
Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Canadian Resource Property - Paragraph (d) Q.2 - a Canadian resource royalty interest requires a right to “take production” 135
Tax Topics - Treaties - Income Tax Conventions - Article 13 Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them 193
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) Q.4 - by analogy to mining, hydrocarbons may be similar properties 348
Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) Q.5 - normal course dispositions of oil and gas properties generally are not of a separate business 131
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) Q.5 - application of Scales test to determining whether there is a separate business 224
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 26 Q.7 - refinery catalysts are Class 26 property 87

Class 50

Administrative Policy

19 September 2013 External T.I. 2013-0498331E5 F - Catégories 29 et 50

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