Schedule II

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

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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"Capital Cost Allowance - Buildings or other Structures"

Class 1(n)

Cases

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

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Class 2

Cases

Gulf Canada Resources Ltd. v. The Queen, 95 DTC 5189 (FCTD), partially rev'd 96 DTC 6065 (FCA).

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Pacific Northern Gas Ltd. v. The Queen, 90 DTC 6252 (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

Cases

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

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

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Words and Phrases
structure

See Also

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 130
Tax Topics - General Concepts - Tax Avoidance taxapyer can argue legally ineffective transactions 131
Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) 74

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

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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 79

Cadillac Fairview Corp. Ltd. v. The Queen, 97 DTC 405 (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 200

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

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

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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. 2004-006478 -

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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 88
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 124
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of constructing cranberry farm basins included in Class 17 71
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 irrigation system included, drainage costs deductible under s. 30 71

Class 7

Administrative Policy

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Vessel vessel is as defined in Canada Shipping Act, 2001 103
Tax Topics - Statutory Interpretation - Interpretation Act - Section 44 - Paragraph 44(h) IA s. 44(h) applied to reference definition in replacement Canada Shipping Act 42

Class 8

Cases

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. The Queen, 92 DTC 6452 (FCTD)

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Pacific Northern Gas Ltd. v. The Queen, 90 DTC 6252 (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

Roy Legumex Inc. v. MNR, 90 DTC 1858 (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 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming zoo not farming 114

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 88
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 124
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 costs of constructing cranberry farm basins included in Class 17 71
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 costs of constructing irrigation pond included 29

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

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Locations of other summaries Wordcount
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 17 142

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

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13 December 1994 T.I. 941607

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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(j)

See Also

Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818

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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 288

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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Administrative Policy

8 January 1996 Memorandum 953067 (C.T.O. "Classification of a Motorhome")

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31 January 1994 T.I. 932897 (C.T.0. "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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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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Administrative Policy

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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1995 Internal T.I. 7-950679 -

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13 April 1994 Memorandum 9400887

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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 62

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 49
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 34

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 142

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 84
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(e) Christmas trees are not “timber” 169

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 256
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(vii) inclusion of cost of completing geothermal exploratory wells in fact used in production 90

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 47

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 Memorandum 941467 (C.T.O. "Film Rights"). (See also 23 August 1995 T.I. 951423 and 3 November 1994 Memorandum 941171)

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9 November 1994 Internal T.I. 7-942518 -

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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

Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818

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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 346

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 102

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 312
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property protean nature of property concept 445

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 88
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 124
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 costs of constructing irrigation pond included 29
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 irrigation system included, drainage costs deductible under s. 30 71

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

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28 June 2001 External T.I. 2001-006842 -

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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 199
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” 129
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 185
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 327
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 123
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) Q.5 - application of Scales test to determining whether there is a separate business 205
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 111

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 (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

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 225

Environnement Sanivac Inc. v. ARQ, 2016 QCCQ 9461

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Locations of other summaries Wordcount
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 255

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 (TCC)

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Lehmann Bookbindings Ltd. v. MNR, 92 DTC 1308 (TCC)

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Roy Legumex Inc. v. MNR, 90 DTC 1858 (TCC)

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Red Deer Adviser Publications Ltd. v. MNR, 89 DTC 520 (TCC)

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Words and Phrases
same transaction

Administrative Policy

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 140

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - manufacturing or processing steel rod plating could qualify 133

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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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 T.I. 940513 (C.T.O. "Wind Turbines")

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2 February 1994 Memorandum 940030 (C.T.O. "Hydroelectric 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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Class 43.1

Administrative Policy

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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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)

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 256
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14 if renegotiation, further permit fees may generate Class 14 property 113

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 199
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” 129
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 185
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 327
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 123
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) Q.5 - application of Scales test to determining whether there is a separate business 205
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 26 Q.7 - refinery catalysts are Class 26 property 81

Class 50

Administrative Policy

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

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