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Quebec to Follow Federal Government on Limiting the Small Business Deduction for CCPCs Earning Passive Income

Quebec’s government announced that it will amend its tax legislation to parallel the federal government’s measure – announced as part of the 2018 budget – to grind down the small business deduction limit for CCPCs having between $50,000 and $150,000 in investment income for taxation years that begin after 2018. Quebec’s government announced the following: […]

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Notice of Ways and Means Motion April 2018: Passive Income, RDTOH, and Small Business Deduction Grind

Passive Investment Income   Budget 2018 Active business income earned by private corporations is taxed at corporate income tax rates that are generally lower than personal income tax rates, giving these corporations more money to invest in order to grow their business. In addition, a small Canadian-controlled private corporation (CCPC) can benefit from a corporate

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IT92R2 – Income of contractors

NO.: IT-92R2 DATE: December 29, 1983 SUBJECT: INCOME TAX ACT Income of Contractors REFERENCE: Subsection 9(1) (also section 125.1, subsections 127(5) and 248(1) and paragraphs 20(1)(gg) and 20(1)(m)) This bulletin replaces and cancels IT-92 dated March 3, 1975. Current revisions are designated by vertical lines. 1. This bulletin applies to any prime contractor or subcontractor who is

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Income Tax Folio S4-F8-C1, Business Investment Losses

Series 4: Businesses Folio 8: Losses Chapter 1: Business Investment Losses Summary A taxpayer’s business investment loss is basically a capital loss from a disposition of shares in, or a debt owing to the taxpayer by, a small business corporation (SBC) where the disposition is: to an arm’s-length person; or one to which subsection 50(1) applies. One-half of this loss

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Income Tax Folio S4-F15-C1, Manufacturing and Processing

Income Tax Folio S4-F15-C1, Manufacturing and Processing Series 4: Businesses Folio 15: Manufacturing and Research & Development Chapter 1: Manufacturing and Processing Summary Section 125.1 provides for the taxation of corporations at a reduced rate on their Canadian manufacturing and processing profits. This takes the form of a deduction from Part I tax otherwise payable and is an amount

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Income Tax Folio S3-F2-C1, Capital Dividends

Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the

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The “More Than Five Full-Time Employees” Test

The “More Than Five Full-Time Employees” Test In 489599 B.C. Ltd. v. The Queen, 7 a CCPC had five full‑time employees and two part‑time employees. The issue was whether the CCPC employed “more than five full‑time employees” for the purposes of the definition of “personal services business” set forth in subsection 125(7). The Tax Court of Canada concluded

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IT168R3- Athletes and players employed by football, hockey and similar clubs

NO: IT-168R3 DATE: May 13, 1991 SUBJECT: INCOME TAX ACT Athletes and Players Employed by Football, Hockey and Similar Clubs REFERENCE: Section 6 (subsection 2(3), sections 8, 115 and 212 and paragraphs 18(1)(p) and 125(7)(d) and the definitions of “retirement compensation arrangement” and “salary deferral arrangement” in subsection 248(1)) Application This bulletin cancels and replaces Interpretation

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IT113R4- Benefits to Employees – Stock Options

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

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IT189R2- Corporations used by practicing members of professions

NO: IT-189R2 DATE: May 24, 1991 SUBJECT: INCOME TAX ACT Corporations Used by Practising Members of Professions REFERENCE: Sections 9 and 125 (also sections 10 and 34 and paragraph 18(1)(p)) Application This bulletin cancels and replaces Interpretation Bulletin IT-189R dated February 27, 1984. Current revisions are indicated by vertical lines. Summary This bulletin deals with corporations

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