Words and Phrases - "structure"
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T
The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor...
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Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(5) - Paragraph 1102(5)(a) - Subparagraph 1102(5)(a)(iii) | rendering of an empty shell suitable for manufacturing constituted substantially changing its nature | 288 |
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(b) | property does not satisfy the “solely” test in Class 8(b) where it was necessary for the proper functioning of the building | 265 |
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | cost of installing property part of that property’s cost | 357 |
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(4) | to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property | 225 |
Tax Topics - General Concepts - Ownership | leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise | 101 |
8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping
Regarding the classification of a septic tank on a campground, the Directorate referred to Superior Pre-Kast Septic Tanks ([1978] 2 S.C.R. 612),...
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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 17 - Paragraph 17(c) | costs of developing a campground would generally be added to Class 17(c) | 98 |
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(17) | campground, if a business, not subject to leasing property restriction rule | 108 |
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 6 | swimming pool is a water storage tank | 98 |
British Columbia Forest Products Ltd. v. MNR, 71 DTC 5178, [1971] CTC 270 (SCC)
Supporting piers, reinforced concrete foundations and chest walls which facilitated and were necessary for the production of paper nonetheless had...
The Queen v. Hampton Golf Club Ltd., 86 DTC 6513, [1986] 2 CTC 403 (FCTD)
Golf Club greens and tees were "not so obviously artificial as to be readily distinguishable from the natural earth surroundings of the rest of...
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Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 1 | 45 |
Suncor Energy Inc. v. The Queen, 2001 DTC 660 (TCC), aff'd 2002 DTC 7395, 2002 FCA 350
The taxpayer used the overburden and tailings produced or extracted by it in the process of extracting bitumen from oil sands deposits to...
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | 141 |
IT-79R3 "Capital Cost Allowance - Buildings or other Structures"
Meaning of building/structure
1. "Building" is a term of wide range covering any structure with walls and a roof affording protection and shelter....