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 […]
Series 3: Property, Investments and Savings Plans Folio 4: Capital Cost Allowance Chapter 1: General Discussion of Capital Cost Allowance Summary Capital cost allowance (CCA) replaces accounting depreciation for income tax purposes. A taxpayer who acquires and uses depreciable property to earn income from a business or property is generally entitled to claim a portion of the capital
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FACTS Jobin owned shares in Groupe AST (assume FMV = $13 million and ACB = $nil). He received an offer for his shares from a third-party purchaser. To minimize his taxes, Jobin undertook the following steps. Jobin rolled his shares in Groupe AST – which had a fair market value of $13 million – on
2763478 Canada Inc. v. Canada Summary Click here for our summary of this case. Court (s) Database Federal Court of Appeal Decisions Date 2018-11-15 Neutral citation 2018 FCA 209 File numbers A-243-17 CORAM: NOËL C.J. BOIVIN J.A. DE MONTIGNY J.A BETWEEN: 2763478 CANADA INC. Appellant and HER MAJESTY THE QUEEN Respondent Heard at Montréal ,
NO: IT-467R2 DATE: November 13, 2002 SUBJECT: INCOME TAX ACT Damages, Settlements and Similar Payments REFERENCE: Paragraphs 18(1)(a), (b), (c), (h) and (e) (also section 67, subsection 40(1), the definition of “eligible capital expenditure” in subsection 14(5), and paragraphs 20(1)(z) and 20(1)(z.1)) Application This bulletin cancels and replaces IT-467R, Damages, Settlements and Similar Payments, dated February 19,
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NO.: IT-268R3 DATE: February 13, 1987 SUBJECT: INCOME TAX ACT Inter Vivos Transfer of Farm Property to Child REFERENCE: Subsections 73(3) and 73(4) (also sections 69, 75, 75.1, 80 and 110.6, subsections 40(1), 40(1.1), 70(9.6), 70(9.8), 70(10), 73(5), 100(2), 146(5.3), 146(5.4), 146(5.5), 248(1) and 252(1) and paragraphs 40(2)(b), 40(2)(c) and 54(g) of the Income Tax Act; subsections 20(1), 21(1), 21(2), 26(3), 26(5) and 26(19) of the Income Tax Application
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Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Series 4: Businesses Folio 7: Wind-ups, Dissolutions and Amalgamations Chapter 1: Amalgamations of Canadian Corporations Summary This Chapter outlines the Canada Revenue Agency’s (CRA) views on a number of issues relating to the amalgamation of two or more taxable Canadian corporations as described in subsection 87(1) (referred to in this
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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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NO.: IT-95R DATE: December 16, 1980 SUBJECT: INCOME TAX ACT Foreign Exchange Gains and Losses REFERENCE: Subsection 9(1) (Also subsections 39(2), 40(1) and 40(2) of the Act) This bulletin replaces and cancels IT-95, dated March 15, 1973. 1. There are no provisions in the Act which specify whether a foreign exchange gain or loss is on account of
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