S4-F15-C1, Manufacturing and Processing

Introduction

The purpose of a Chapter History page is to highlight any amendments to the information contained in an interpretation bulletin that is now reflected in a chapter of an income tax folio as well as to identify any subsequent amendments to a folio chapter. It outlines amendments that have been made as a result of legislative changes and proposed legislative changes, precedential court decisions, as well as new or revised interpretations of the Canada Revenue Agency (CRA).

Except as otherwise noted, all statutory references herein are references to provisions of the Income Tax Act, R.S.C., 1985, c.1 (5th Supp.), as amended and all references to a Regulation are to the Income Tax Regulations, C.R.C., c. 945, as amended.

Update February 16, 2017

The wording in ¶1.20, ¶1.25, ¶1.44 and ¶1.52 of the French version only has been revised for readability purposes.

¶1.28 and 1.32 have been revised to improve consistency in the use of the term “related” versus “associated”.

Example 2 has been revised to clarify that Corporation B is related to Corporation A and to refer to “bien” instead of “bâtiment” in the second paragraph. These changes affect only the French version of the Chapter.

Update September 27, 2016

General

Income Tax Folio S4-F15-C1, Manufacturing and Processing, replaces and cancels Interpretation Bulletin IT-147R3, Capital Cost Allowance – Accelerated Write-off of Manufacturing and Processing Machinery and Equipment.

In addition to consolidating the content of the former interpretation bulletin, general revisions have been made to improve readability. Any substantive technical and interpretive changes to the information outlined in the former interpretation bulletin are described below.

The content under the heading Manufacturing and processing profits deduction – M&P credit (¶1.1 - 1.43) is substantially the same as the content previously contained in ¶1 - 35 of Interpretation Bulletin IT-145R (Consolidated), – Canadian Manufacturing and Processing Profits – Reduced Rate of Corporate Tax (Cancelled).

Legislative and other changes

¶1.44 has been added to discuss the capital cost allowance rate and the half-year rule applicable to Class 29 of Schedule II of the Regulations. Former ¶1 and 2 of IT-147R3 have been removed as the content is outdated.

¶1.45 has been added to discuss the relevant timing in subparagraph (c)(iii) of Class 29.

¶1.46 (formerly ¶3 of IT-147R3) has been revised to include Canadian field processing to correspond to subparagraph (a)(ii) of Class 29.

¶1.48 (formerly ¶4 of IT-147R3) has been revised to include a reference to subparagraph (b)(vi) of Class 29. Former ¶5 - 8 of IT-147R3 have been removed as the content is not specific to the topic of manufacturing or processing. Former ¶17 of IT-147R3 has been removed as part of the content is outdated and part is discussed in ¶1.45.

¶1.49 has been added to discuss Class 43 of Schedule II of the Regulations.

¶1.50 has been added to discuss Class 53 of Schedule II of the Regulations.

¶1.58 - 1.61 have been added to discuss qualified property for purposes of an investment tax credit.