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Prior to 1994, there was a limitation on the amount of ITCs that could be utilized in a taxation year. Specifically, in most cases, ITCs could only be used to offset up to 75 per cent of a taxpayer's federal income tax and surtax otherwise payable. For CCPCs, a special rule permitted the full offset of federal tax on their business income eligible for the small business deduction. The annual ITC limitation had been introduced to reduce the number of large corporations that were profitable but did not pay income tax. However, as announced in the 1993 budget, the introduction of the large corporations tax eliminated the need for the annual ITC limitation and investment tax credits became fully deductible for all taxpayers for taxation years beginning after 1993.
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