Words and Phrases - "processing"

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

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

An operation of the taxpayer consists of taking products, received in bulk in boxes, and dividing them up by category according to specific...

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Words and Phrases
processing
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 equipment used in dividing and repackaging bulk goods was not “processing” equipment 164

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

greenhouse heating equipment was used in non-farming manufacturing of floral arrangements

The taxpayer used approximately 20% of the area within greenhouses to grow cucumbers or other vegetables, or flowers, from seed for sale as...

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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

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

“integration principle” applied to find that a jetty was a “processing” asset

The taxpayers were the partners of a limited partnership which constructed a terminal and jetty in St. John to which liquid natural gas would be...

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

LNG regasification jetty and terminal were one asset for processing before distribution

The taxpayers were related companies, and the general partner and a 75% limited partner of a partnership which constructed a terminal and jetty in...

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Words and Phrases
distribution processing

Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA)

only operations significantly changing goods' character are "manufacturing" or "processing"

In finding that a corporation which assembled and installed exhaust systems in automobiles was not engaged in manufacturing ("producing for sale...

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Words and Phrases
manufacturing processing