Income Tax Regulations — 5202
ion for a taxation 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 of the corporation during 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 of the corporation during the year if those persons were employees of the corporation, 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 to a particular person of a property at any time means, in respect of property that has become available for use by the particular person for the purposes of subsection 13(26) of the Act, the capital cost to the particular person of the property computed without reference to subsections 13(7.1), (7.4) and (10), sections 21 and 80 and paragraph 111(4)(e) of the Act and, in respect of any other property, nil, and where the particular person acquired the property (a) in the course of a reorganization in respect of which, if a dividend were received by the particular person in the course of the reorganization, subsection 55(2) of the Act would not apply to the dividend by reason of the application of paragraph 55(3)(b) of the Act, or (b) from another person with whom the particular person was not dealing at arm’s length (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act) immediately after the property was acquired, the capital cost to the particular person of the property for the purposes of this definition shall be computed as if the property had been acquired at a capital cost equal to the gross cost of the property to the person from whom the property was acquired by the particular person; ( coût brut ) qualified activities means (a) any of the following activities, when they are performed in Canada in connection with manufacturing or processing (not including the activities listed in paragraphs (a) to (k) of the definition manufacturing or processing in subsection 125.1(3) of the Act) in Canada of goods for sale or lease: (i) engineering design of products and production facilities, (ii) receiving and storing of raw materials, (iii) producing, assembling and handling of goods in process, (iv) inspecting and packaging of finished goods, (v) line supervision, (vi) production support activities including security, cleaning, heating and factory maintenance, (vii) quality and production control, (viii) repair of production facilities, and (ix) pollution control, (b) all other activities that are performed in Canada directly in connection with manufacturing or processing (not including the activities listed in paragraphs (a) to (k) of the definition manufacturing or processing in subsection 125.1(3) of the Act) in Canada of goods for sale or lease, and (c) scientific research and experimental development, as defined in section 2900, carried on in Canada, but does not include any of (d) storing, shipping, selling and leasing of finished goods, (e) purchasing of raw materials, (f) administration, including clerical and personnel activities, (g) purchase and resale operations, (h) data processing, and (i) providing facilities for employees, including cafeterias, clinics and recreational facilities; ( activités admissibles ) qualified zero-emission technology manufacturing activities means (a) qualified activities that are (i) performed in connection with the manufacturing or processing of (A) solar energy conversion equipment, including solar thermal collectors, photovoltaic solar arrays and custom supporting structures or frames, but excluding passive solar heating equipment, (B) wind energy conversion equipment, includ