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 […]
Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former
Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former
Income Tax Folio S3-F8-C2, Tax Incentives for Clean Energy Equipment Series 3: Property Investments and Savings Plans Folio 8: Resource Properties Chapter 2: Tax Incentives for Clean Energy Equipment Summary The Income Tax Act and Income Tax Regulations include the following measures to encourage Canadian taxpayers to make investments in qualifying clean energy generation and energy conservation projects: an
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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-F16-C1, What is a Partnership? Series 4: Businesses Folio 16: Partnerships Chapter 1: What is a Partnership? Summary The Act does not define a partnership but it recognizes the existence of partnerships and sets out the income tax consequences of transactions involving partnerships and their members. Section 96 provides that the income of a
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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-278R2 DATE: September 26, 1994 SUBJECT: INCOME TAX ACT Death of a Partner or of a Retired Partner REFERENCE: Section 98.1 (also sections 34, 43, 98.2, 110.6, subsections 40(3), 53(1), 53(2), 70(2), 70(3), 70(5), 70(6), 96(1), 96(1.1), 96(1.3), 96(1.5), 96(3), 100(2), 100(3, 150(4), 159(5), 159(5.1) and paragraph 12(1)(l) of the Income Tax Act, and subsections
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NO: IT-262R2 DATE: November 28, 1996 SUBJECT: INCOME TAX ACT Losses of Non-Residents and Part-Year Residents REFERENCE: Section 114, subsection 111(9) and paragraphs 115(1)(c) and 115(1)(e) (also sections 3, 31 and 80 and subsections 2(3), 96(2.1), 111(1), 111(1.1), 111(3) and 111(8)) Application This bulletin cancels and replaces IT-262R dated August 30, 1985. Summary The Income Tax Act contains a system of rules
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NO: IT-123R6 DATE: June 1, 1997 SUBJECT: INCOME TAX ACT Transactions Involving Eligible Capital Property REFERENCE: Section 14 (also sections 102 and 110.6; the definition of “eligible capital property” in section 54; subsections 20(4.2), 24(1), 39.1(5), 96(1), 104(21) and 104(21.2); the definition of “capital dividend account” in subsection 89(1), the definition of “exempt capital gains balance” in subsection 39.1(1) and the definitions
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