processing

23 April 2024 External T.I. 2024-1004511E5 - AITC and fuel production -- summary under Subparagraph (c)(i)

Whether equipment acquired by the taxpayer constituted qualified property for the purposes of claiming the Atlantic investment tax credit (AITC) turned, in part, on whether it constituted depreciable property referred to in Reg 4600(2). This, in turn, appeared to turn largely on whether its use in the production or processing of fuel could be considered to be the manufacturing or processing of goods for sale in the context of the description of a Class 29 property, and as also required by the definition of “qualified property” in s. 127(9).

22 January 2009 External T.I. 2008-0290971E5 F - Bénéfices de fabrication et de transformation -- summary under Canadian Manufacturing and Processing Profits

An operation of the taxpayer consists of taking products, received in bulk in boxes, and dividing them up by category according to specific customer instructions, such as size, colour and quantity, then packaging the products for sale and distribution to consumers.

By services, 25 November, 2019

Coop de travailleurs en serres Belle-de-Jour v. Agence du revenu du Québec, 2019 QCCQ 6609 -- summary under Class 29

The taxpayer used approximately 20% of the area within greenhouses to grow cucumbers or other vegetables, or flowers, from seed for sale as grocery items or as little plants that could be transplanted. The taxpayer also annually produced about 85,000 floral arrangements in pots, which it sold to retailers such as Costco.

By services, 27 September, 2017

Canada v. Repsol Energy Canada Ltd., 2017 FCA 193 -- summary under Paragraph 1(n)

The taxpayers were the partners of a limited partnership which constructed a terminal and jetty in St. John to which liquid natural gas would be delivered by tanker (at the jetty), "regasified,", and then delivered to a pipeline for shipment to the U.S. resellers.

By services, 28 November, 2015

Repsol Canada Ltd. v. The Queen, 2015 TCC 21, aff'd 2017 FCA 193 -- summary under Class 1

The taxpayers were related companies, and the general partner and a 75% limited partner of a partnership which constructed a terminal and jetty in St. John to which liquid natural gas would be delivered by tanker (at the jetty), "regasified," tested and processed to meet quality standards such as flammability and low O₂ content, and then delivered to a pipeline for shipment to the U.S. resellers.

By services, 28 November, 2015

Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA) -- summary under Canadian Manufacturing and Processing Profits

In finding that a corporation which assembled and installed exhaust systems in automobiles was not engaged in manufacturing ("producing for sale an identifiable article of commerce by assembling parts produced by others" (p. 5208)) or processing (which "occurs when raw or natural materials are transformed into saleable items" (p. 5209)), Linden J.A. stated (pp. 5209-5210):

processing

processing

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