21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA -- summary under Government Assistance

A non-CCPC Canadian corporation acquires solar equipment for $10,000,000 in 2024 for immediate use in generating electricity as an input in its manufacturing operation in Nova Scotia.

It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund.

It also claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate).

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period.

Topics and taglines
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
905268
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
905270
Extra import data
{
"field_editor_tags": [],
"field_roundtable_subquestion": "",
"field_stub": false,
"field_legacy_header": ""
}
Workflow properties
Workflow state