CRA Interpretations

IT154R- Special reserves

NO: IT-154R DATE: February 19, 1988 SUBJECT: INCOME TAX ACT Special Reserves REFERENCE: Paragraphs 20(1)(m), (m.1), (m.2) and (n) (also subsections 20(6), (7), (8), (24) and (25), 88(1) and 28(1) and paragraphs 12(1)(a) and (e), 72(1)(a) and 87(2)(i) and (j)) Application This bulletin cancels and replaces Interpretation Bulletin IT-154 dated March 14, 1974. Current revisions are […]

IT154R- Special reserves Read More »

IT243R4- Dividend Refund to Private Corporations

NO: IT-243R4 DATE: February 12, 1996 SUBJECT: INCOME TAX ACT Dividend Refund to Private Corporations REFERENCE: Section 129 (also sections 51, 84, 85.1, 86, 87, 88, 105, 123.2, 125, 150, and 157; subsections 12(10.2), 15(3), 85(1), 104(13) and (14), 126(1) and (2), 161(2), 186(2), 256(2), and 260(7); the definitions of “designated property” and “private corporation” in

IT243R4- Dividend Refund to Private Corporations Read More »

IT242R- Retired Partners

NO: IT-242R DATE: September 6, 1991 SUBJECT: INCOME TAX ACT Retired Partners REFERENCE: Section 98.1 (also sections 43, 48, 96, 98.2, 110.6, subsections 40(3), 53(1), 53(2), 70(6), 85(3), paragraph 70(5)(a), and subparagraph 115(1)(b)(v); subsections 23(3) and (4) of the Income Tax Application Rules, 1971 (ITAR); and section 2600 of the Income Tax Regulations) Application This bulletin

IT242R- Retired Partners Read More »

IT238R2- Fees paid to investment counsel

NO: IT-238R2 DATE: October 6, 1983 SUBJECT: INCOME TAX ACT Fees Paid to Investment Counsel REFERENCE: Paragraph 20(1)(bb) This bulletin replaces and cancels IT-238R dated November 15, 1976. Current revisions are indicated by vertical lines. 1. Paragraph 20(1)(bb) allows a taxpayer to deduct fees, other than commissions, paid for advice on buying or selling a specific

IT238R2- Fees paid to investment counsel Read More »

IT231R2- Partnerships – Partners not dealing at arm’s length

NO: IT-231R2 DATE: March 3, 1986 SUBJECT: INCOME TAX ACT Partnerships – Partners not Dealing at Arm’s Length REFERENCE: Subsection 103(1.1) IT231R2 Partnerships – Partners not dealing at arm’s length This bulletin replaces and cancels Interpretation Bulletin IT-231R dated November 21, 1977. 1. This bulletin discusses the sharing of income from partnerships by partners who do

IT231R2- Partnerships – Partners not dealing at arm’s length Read More »

IT143R3-Meaning of Eligible Capital Expenditure

NO: IT-143R3 DATE: August 29, 2002 SUBJECT: INCOME TAX ACT Meaning of Eligible Capital Expenditure REFERENCE: The definition of “eligible capital expenditure” in subsection 14(5) (also sections 68 and 69, the definition of “eligible capital property” in section 54, the definition of “cumulative eligible capital” in subsection 14(5), and paragraphs 13(7.5)(b), (c) and (d) of the Income

IT143R3-Meaning of Eligible Capital Expenditure Read More »

IC89-4 Tax Shelter Reporting

Tax Shelter Reporting NO.: 89-4 DATE: August 14, 1989 SUBJECT: Tax Shelter Reporting 1. The purpose of this circular is to set out guidelines to assist the promoter of a tax shelter to prepare and file: (a) the application form necessary to obtain a tax shelter identification number; and (b) the tax shelter information return and supporting supplementaries.

IC89-4 Tax Shelter Reporting Read More »

IC89-3 Policy Statement on Business Equity Valuations

Policy Statement on Business Equity Valuations NO.: 89-3 DATE: August 25, 1989 SUBJECT: Policy Statement on Business Equity Valuations 1. This Information Circular outlines the valuation principles, practices and policies that the Department generally considers and follows in the valuation of securities and intangible property of closely-held corporations for income tax purposes. Law 2. All valuations should be

IC89-3 Policy Statement on Business Equity Valuations Read More »

Scroll to Top
Scroll to Top