Income Tax Regulations — 5204
od, as the case may be, but for the purposes of this definition, the salaries and wages referred to in paragraph (a) or other amounts referred to in paragraph (b), of the corporation or the partnership, as the case may be, do not include that portion of those amounts that (d) was included in the gross cost to the corporation or partnership of a property (other than a property that was manufactured by the corporation or partnership and leased during the year by the corporation or the partnership to another person) that was included in computing the cost of capital of the corporation for the year, (e) was related to an active business carried on outside Canada by the corporation or the partnership, (f) was related to the activities engaged in for the purpose of earning Canadian resource profits of the corporation or the partnership, as the case may be, or (g) was included in the Canadian exploration and development expenses, foreign exploration and development expenses, Canadian exploration expense or Canadian development expense, within the meanings assigned by paragraphs 66(15)(b) and (e), 66.1(6)(a) and 66.2(5)(a) of the Act respectively, of the corporation; ( coût en main-d’oeuvre ) cost of manufacturing and processing capital of the corporation for the year means 100/85 of that portion of the cost of capital of the corporation for that year that reflects the extent to which each property included in the calculation thereof was used directly in qualified activities (a) of the corporation during the year, or (b) of the partnership during its fiscal period coinciding with or ending in the year, as the case may be, but the amount so calculated shall not exceed the cost of capital of the corporation for the year; ( coût en capital de fabrication et de transformation ) cost of manufacturing and processing labour of the corporation for the year means 100/75 of that portion of the cost of labour of the corporation for that year that reflects the extent to which (a) the salaries and wages included in the calculation thereof were paid or payable to persons for the portion of their time that they were directly engaged in qualified activities (i) of the corporation during the year, or (ii) of the partnership during its fiscal period coinciding with or ending in the year, and (b) the other amounts included in the calculation thereof were paid or payable to persons for the performance of functions that would be directly related to qualified activities (i) of the corporation during the year, or (ii) of the partnership during its fiscal period coinciding with or ending in the year, if those persons were employees of the corporation or the partnership, as the case may be, but the amount so calculated shall not exceed the cost of labour of the corporation for the year; ( coût en main-d’oeuvre de fabrication et de transformation ) gross cost of a property at any time means (a) in respect of a property that has become available for use by the partnership for the purposes of subsection 13(26) of the Act, the capital cost to the partnership of the property computed without reference to subsections 13(7.1), (7.4) and (10) and sections 21 and 80 of the Act, and (b) in respect of any other property of the partnership, nil, and, for the purposes of paragraph (a), if the partnership acquired the property from a person who was a majority-interest partner of the partnership immediately after the property was acquired, the capital cost to the partnership of the property is to be computed as if the property had been acquired at a capital cost equal to the gross cost to the person of the property, except that if the property was partnership property on December 31, 1971, its gross cost is its capital cost to the partnership as determined under subsection 20(3) or (5) of the Income Tax Application Rules ; ( coût brut ) ZETM cost of capital , of the corporation for the year, means the portion of the cost of capital of the corporation for that year that refl