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IT438R2- Crown Charges – Resources Properties in Canada

NO.: IT-438R2 DATE:   April 21, 1995 SUBJECT: INCOME TAX ACT Crown Charges – Resource Properties in Canada REFERENCE: Paragraphs 12(1)(o) and 18(1)(m) (also section 80.2, subsections 66.2(2), 66.4(2), 69(6) to (10) and 214(1), paragraph 212(1)(d), the definition “Canadian development expense” in subsection 66.2(5) and the definition “Canadian oil and gas property expense” in subsection 66.4(5) of the […]

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Convertible Debt

Convertible Debt Subsection 214(7) applies to deem interest to be paid by a person resident in Canada to a non-resident person where a non-resident person assigns or otherwise transfers to a person resident in Canada a debt obligation issued by a person resident in Canada. The amount deemed to be interest is equal to the

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IT468R- Management or administration fees paid to non-residents

NO: IT-468R DATE: December 29, 1989 SUBJECT: INCOME TAX ACT Management or administration fees paid to non-residents REFERENCE:PARAGRAPH 212(1)(A) (ALSO SECTION 67, SUBSECTIONS 69(2), 212(2) AND 212(4) AND PARAGRAPH 214(3)(A)) APPLICATION This bulletin replaces and cancels IT-468 dated February 2, 1981. Current revisions are designated by vertical lines. SUMMARY This bulletin deals with the tax treatment

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IT119R4- Debts of Shareholders and Certain Persons Connected With Shareholders.

NO: IT-119R4 DATE: August 7, 1998 SUBJECT: INCOME TAX ACT Debts of Shareholders and Certain Persons Connected With Shareholders REFERENCE: Subsection 15(2) (also subsections 15(1), 15(1.2), 15(2.1) to (2.7), 15(7), 15(9), 212(2), 214(3) and 227(6.1), 248(1) definitions of “foreign affiliate” and “specified employee” and paragraph 20(1)(j)) Application This bulletin cancels and replaces Interpretation Bulletin IT-119R3, dated

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IT432R2- Benefits Conferred on Shareholders

NO.: IT-432R2 DATE: February 10, 1995 SUBJECT: INCOME TAX ACT Benefits Conferred on Shareholders REFERENCE: Subsection 15(1) (also sections 84 and 246; subsections 15(1.1) to 15(1.4), 15(7), 52(1), 52(1.1), 56(2) and 248(1) definitions of “property”, “corporation”, “shareholder” and “specified shareholder”; paragraphs 6(1)(a), 69(1)(b), 82(1)(a) and 214(3)(a); and subparagraph 129(1)(a)(i) of the Income Tax Act; and

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