Series 3: Property, Investments and Savings Plans Folio 3: Capital Transactions Chapter 1: Replacement Property Summary Subsections 13(4) and 44(1) permit a taxpayer to elect to defer the recognition of recapture (income) of capital cost allowance (CCA) or capital gains where a property was involuntarily disposed of, or a former business property was voluntarily disposed […]
Residency of a corporation What is a Canadian corporation? Section 89 of the ITA defines a Canadian corporation as one that is resident in Canada and was: incorporated in Canada; or resident in Canada from June 18, 1971, to the present A corporation formed by a corporate reorganization is a Canadian corporation due to incorporation in Canada
NO.: IT-206R DATE: October 29, 1979 SUBJECT: INCOME TAX ACT Separate businesses REFERENCE: Section 3 (also sections 14 and 128, subsection 111(5); and Regulations 1101(1) and 2605) This bulletin replaces and cancels Interpretation Bulletin No. IT-206 dated April 14, 1975. Current revisions are designated by vertical lines. 1. The question of whether a taxpayer is conducting one business
Series 5: International and Residency Folio 1: Residency Chapter 1: Determining an Individual’s Residence Status Summary The purpose of this Chapter is to explain the position of the Canada Revenue Agency (CRA) concerning the determination of an individual’s residence status for income tax purposes and the factors to be taken into account in making that determination.
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Income Tax Folio S5-F2-C1, Foreign Tax Credit Series 5: International and Residency Folio 2: Foreign Tax Credits and Deductions Chapter 1: Foreign Tax Credit Summary Section 126 of the Act makes a foreign tax credit available to a taxpayer who at any time in a year is a resident of Canada, or in certain limited circumstances is
NO: IT-259R4 DATE: September 23, 2003 SUBJECT: INCOME TAX ACT Exchange of Property REFERENCE: Section 44 and subsections 13(4), 13(4.1), 14(6) and 14(7) of the Income Tax Act (the Act) (also sections 70 and 128.1, paragraphs 87(2)(l.3), 88(1)(a) and 96(1)(a) and subparagraph 40(1)(a)(iii) and the definition of “proceeds of disposition” in section 54 and subsection 13(21) of the
NO: IT-113R4 DATE: August 7, 1996 SUBJECT: INCOME TAX ACT Benefits to Employees – Stock Options REFERENCE: Section 7 (also subsections 2(3), 5(1), 8(12), 110(1.5), 115(1) and the definition of “Canadian-controlled private corporation” in subsection 125(7), paragraphs 6(1)(a), 53(1)(j) and 110(1)(d) and (d.1), and subparagraph 128.1(4)(b)(vi) of the Income Tax Act; and section 6204 of the
NO: IT-124R6 DATE: January 31, 1995 SUBJECT: INCOME TAX ACT Contributions to Registered Retirement Savings Plan REFERENCE: REFERENCE:Subsections 146(5) and (5.1) (also sections 60.01 and 204.1 to 204.3 and the definition of “disposition” in section 54; subsections 104(10.2), (27) and (27.1), 146(1), (2), (3), (6.1), (8.2), (8.21) and (8.3), 146.3(5.1), 147.1(1), 147.3(13.1) and 152(6); and paragraphs
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