9 May 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656233
Extra import data
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"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [JN91_149.150 - MA91_334.338]/MA91_162 — Ontario Research and Development Super Allowance and the Ontario Current Cost Adjustment"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-05-09 08:00:00",
"field_tags": []
}
Main text
910469
          24(1)                              C.R. Brown
                                             (613) 957-2135
          19(1)

May 9, 1991

Dear Sir:

Re: Subsection 127(9)

This is in reply to your letter of February 12, 1991 concerning the Province of Ontario Research and Development Super Allowance and the Ontario Current Cost Adjustment. These programs allow corporations subject to Ontario income tax to claim special deductions in computing taxable income. If the corporation qualifies for the Super Allowance deductions are allowed for expenditures on scientific research and experimental development carried out in Ontario. The Current Cost Adjustment is a deduction allowed for new manufacturing and processing capital machinery and equipment purchased after 1988 for use in Ontario.

The Super Allowance, the Current Cost Adjustment and the related provincial tax savings are not considered "government assistance" as that term is defined in paragraph 127(9) of the (Canadian) Income Tax Act (the "Act"). In addition, these amounts are not government assistance for the purposes of paragraph 37(1)(d), 12(1)(x) and subsection 13(7.1) of the Act.

We trust that these comments will be of assistance.

for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

                                                       .../cont'd

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