16 October 1986 Income Tax Severed Letter 7-0925 - [Section 8 B.C. Income Tax Act]

By services, 22 July, 2022
Official title
[Section 8 B.C. Income Tax Act]
Language
English
Document number
Citation name
7-0925
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657090
Extra import data
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"field_release_date_new": "1986-10-16 08:00:00",
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Main text

October 16, 1986

TO        PENTICTION DISTRICT OFFICE
ATTENTION M. Scott
          Basic FIles
FROM      D. Senecal
          Resource Industries
            Section

RE: Section 8 B.C. Income Tax Act

This is in reply to your memorandum of February 4, 1986, concerning the B. C. Royalty and Deemed Income Rebate which was recently forwarded to us by Provincial & International Relations Division for our consideration and response.

In our view, subsections 8(4) and 8(5) of the B.C. Income Tax Act clearly require P.I.P. grants to be added to the taxpayer's notional income for purposes of calculating the royalty and deemed income rebate. We agree with your comments that the actual taxable income of the taxpayer will already have been increased in the year to the extent that the claim: for C.E.E. or C.D.E. has been reduced by P.I.P. grants. While this result may not have been intended, an amendment to the Act would be required to correct the situation.

We also concur with your conclusion that no addition is required to be made to the B.C. notional income with respect to any Alberta Royalty Tax Credits received by the taxpayer.

C. Savage

Chief Resource Industries Section Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch