Regulation 5202 - Interpretation

Adjusted Business Income

See Also

Irving Oil Ltd. v. The Queen, 2000 DTC 2164 (TCC)

In finding that refund interest received by the taxpayer following a successful appeal of a substantial assessment represented business income...

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Administrative Policy

11 April 1995 Internal T.I. 7-942949

Interest earned on overpayments of taxes are not income from an active business.

Cost of capital

Normally

Rental Cost

Cost of Labour

See Also

NRB Inc. v. The Queen, 93 DTC 295 (TCC)

The taxpayer, which used employees throughout the year to manufacture and erect modular buildings, was able to treat amounts paid to...

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Cost of Manufacturing and Processing Capital

See Also

D.MNR for Customs and Excise v. Amoco Canada Petroleum Co. Ltd., 86 DTC 6008, [1986] 1 CTC 124 (FCA)

The word "directly" in s. 1(a) of Part XIII of Schedule III to the Excise Tax Act was found to have a broad meaning of "without any intervening...

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Words and Phrases
directly
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Ordinary Meaning 25

Cost of Manufacturing and Processing Labour

Administrative Policy

9 October 1990 Memorandum (Tax Window, Prelim. No. 1, p. 23, ¶1030)

Where the cost of foreign-based engineering designs of products and production facilities is included in amounts charged to a Canadian corporation...

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Qualified Activities

Cases

St. Catharines Standard Ltd. v. The Queen, 78 DTC 6168, [1978] CTC 258 (FCTD)

The receiving and storing of news by reporters at a newspaper, the researching and writing of articles or the preparation of advertisements, and...

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See Also

Lomex Inc. v. MNR, 92 DTC 2253 (TCC)

An operation of transporting animal residues (e.g., bones, meatscraps, feathers, blood and offal) by specially-adapted trucks to the taxpayer's...

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Words and Phrases
directly

Administrative Policy

November 1991 Memorandum (Tax Window, No. 13, p. 13, ¶1578)

Minerals extracted from a mineral resource which have not been subsequently manufactured or processed do not constitute finished goods.

91 CPTJ - Q.30

Oil and gas which has been extracted and which is not yet been subsequently manufactured or processed does not constitute finished goods.

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