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
combined effect of NS CITC and clean tech ITC
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 manufacturing operation in Nova Scotia.
It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund.
It also claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate).
| 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 |