20(1)

Income Tax Folio S4-F2-C1, Deductibility of Fines and Penalties

Income Tax Folio S4-F2-C1, Deductibility of Fines and Penalties Series 4: Businesses Folio 2: Deducting Business Expenses Chapter 1: Deductibility of Fines and Penalties Summary This Chapter discusses the deductibility of fines and penalties for income tax purposes. Several provisions of the Act deny the deduction of a fine or penalty. The key provision is section […]

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Income Tax Folio S3-F6-C1, Interest Deductibility

Income Tax Folio S3-F6-C1, Interest Deductibility Series 3: Property, Investments, and Savings Plans Folio 6: Interest Chapter 1: Interest Deductibility Summary The purpose of this Chapter is to explain the Canada Revenue Agency’s (CRA) position on the deductibility of interest expense under paragraph 20(1)(c). The Chapter also discusses various other provisions of the Act relating to interest deductibility. An amount

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Income Tax Folio S3-F9-C1, Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

Income Tax Folio S3-F9-C1, Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime Series 3: Property, Investments and Savings Plans Folio 9: Miscellaneous Payments/Receipts Chapter  1:  Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime Summary This Chapter discusses the tax treatment of various receipts, such as strike pay, gambling winnings, and forfeited

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TN-44-Exchangeable Debentures

Exchangeable Debentures: Paragraph 20(1)(f) Question 1 At the Canadian Tax Foundation’s 2008 annual conference,[Footnote 18] the CRA was asked to provide its views in respect of the application of paragraph 20(1)(f) to exchangeable debentures in light of the Federal Court of Appeal decision in Tembec Inc. et al. v. The Queen.[Footnote 19] The CRA was not prepared to comment at that

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TN-41-Exchangeable Debentures

Exchangeable Debentures – Paragraph 20(1)(f) In Imperial Oil Ltd. v. Canada, 20 the Supreme Court of Canada held that paragraph 20(1)(f) does not apply to foreign currency losses. The CRA stated verbally at the 2006 Canadian Tax Foundation Annual Conference that commodity-based loans and exchangeable debenture financings currently in place would still be eligible for paragraph 20(1)(f) treatment. The

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International Financial Reporting Standards

International Financial Reporting Standards The purpose of this article is to provide guidance on how the requirement for publicly accountable enterprises (PAEs) to adopt International Financial Reporting Standards (IFRS), effective for interim and annual financial statements relating to fiscal years beginning on or after January 1, 2011, will affect those enterprises’ tax reporting. IFRS will

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IT481- Timber Resource Property and Timber Limits

NO: IT-481 (Consolidated) DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT Timber Resource Property and Timber Limits REFERENCE: The definition of “timber resource property” in subsection 13(21) of the Income Tax Act (the “Act”); and subsection 1101(3), paragraph 1100(1)(e), Class 33 of Schedule II and Schedule VI of the Income Tax Regulations (the “Regulations”) (also the definition of “undepreciated capital cost”

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IT99R5- Legal and Accounting Fees

NO.: IT-99R5 (Consolidated)  DATE: See Bulletin Revisions section SUBJECT: INCOME TAX ACT  Legal and Accounting Fees REFERENCE: Paragraph 18(1)(a) (also sections 9 and 239; subsections 13(12), 20(9), and 40(1); paragraphs 6(1)(f), 6(1)(j), 8(1)(b) and (c), 20(1)(b), (e) and (cc), 56(1)(b), (l) and ( l.1), 60(o) and (o.1) and the definitions of “cumulative eligible capital” and “eligible capital expenditure” in subsection

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IT285R2 Capital Cost Allowance – General Comments

Capital Cost Allowance – General Comments NO: IT-285R2 DATE: March 31, 1994 SUBJECT: INCOME TAX ACT Capital Cost Allowance – General Comments REFERENCE: Paragraph 20(1)(a) (also paragraph 18(1)(b) and Part XI of the Income Tax Regulations) Application This bulletin cancels and replaces Interpretation Bulletin IT-285R dated October 11, 1985 and the Special Release to IT-285R dated

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IT261R- Prepayment of rents

NO: IT-261R DATE: May 20, 1980 SUBJECT: INCOME TAX ACT Prepayments of rents REFERENCE: Reference: 9(1), 18(1)(a) (also paragraph 18(1)(b) and subparagraph 20(1)(m)(iii)) This bulletin cancels and replaces Interpretation Bulletin IT-261 dated November 3, 1975 and Special Release dated December 5, 1977. 1. This bulletin deals with prepayments of rent and the treatment of the prepayments

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