Section 127.45

Subsection 127.45(1)

Clean Technology Property

Administrative Policy

15 December 2025 External T.I. 2024-1043191E5 - Clean Technology ITC - Leasehold interest

Would the lessor or the lessee under a lease-to-own arrangement in respect of clean technology property be eligible to claim the clean technology...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127.45 - Subsection 127.45(11) recapture if the lessee acquires the property less than 10 years into the lease under a lease-to-own arrangement 49

Paragraph (d)

Subparagraph (d)(iv)

Administrative Policy

3 October 2025 External T.I. 2025-1075051E5 - Clean Tech ITC: Class 56 equipment

The taxpayer, a taxable Canadian corporation, would acquire a vehicle - that used electricity supplied to it by an attached tether cable to power...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 56 - Paragraph (a) - Subparagraph (a)(i) electric cable car could qualify as fully electric automotive equipment 70

Subsection 127.45(5)

Paragraph 127.45(5)(b.1)

Subparagraph 127.45(5)(b.1(i))

Administrative Policy

21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA

A non-CCPC Canadian corporation acquires solar equipment for $10,000,000 in 2024 for immediate use in generating electricity as an input in its...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) - Element A example of AIIP computation for solar panels 81
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance NS CITC was reasonably expected to be received at year end even though required government certificate not yet applied for 170
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) illustration showing recapture being realized with no disposition 294

Subsection 127.45(11)

Administrative Policy

15 December 2025 External T.I. 2024-1043191E5 - Clean Technology ITC - Leasehold interest

After discussing a lease-to-own arrangement in respect of clean technology property, CRA indicated that if the lessee acquires the property less...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127.45 - Subsection 127.45(1) - Clean Technology Property a lessee will not be able to claim a clean technology ITC under a lease-to-own arrangement 273

Subsection 127.45(14)

Administrative Policy

27 January 2026 External T.I. 2025-1080051E5 - CT-ITC Recapture Rules

Aco, which was related to two other taxable Canadian corporation (Bco and Cco), acquired in Year 1 a clean technology property and claimed the...

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