Words and Phrases - "processing"
22 January 2009 External T.I. 2008-0290971E5 F - Bénéfices de fabrication et de transformation
Summary Under
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profitsoperation 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...
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...
| 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
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 - Paragraph 1(n)“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...
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...
Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profitsonly 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...