Citation: Fundy Settlement v. Canada, 2012 SCC 14, [2012] 1 S.C.R. 520 Date: 20120412 Docket: 34056, 34057 Summary Taxation — Income tax — Trusts — Residence — Trusts held by corporation resident in Barbados — Beneficiaries of trusts resident in Canada — Central management and control of trusts carried out by main trust beneficiaries in Canada — Trustee seeking return […]
NO: IT-286R2 DATE: April 8, 1988 SUBJECT: INCOME TAX ACT Trusts – Amount Payable REFERENCE: Subsection 104(24) (also subsections 52(6), 104(4), (5), (5.1), (6), (13) and (18) and 107(4), paragraph 149(1)(o.4) and subparagraphs 110(1)(a)(i) to (vii)) Application This bulletin cancels and replaces IT-286R dated October 4, 1982. Current revisions are designated by vertical lines. Proposals contained
NO: IT-123R6 DATE: June 1, 1997 SUBJECT: INCOME TAX ACT Transactions Involving Eligible Capital Property REFERENCE: Section 14 (also sections 102 and 110.6; the definition of “eligible capital property” in section 54; subsections 20(4.2), 24(1), 39.1(5), 96(1), 104(21) and 104(21.2); the definition of “capital dividend account” in subsection 89(1), the definition of “exempt capital gains balance” in subsection 39.1(1) and the definitions
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NO: IT-124R6 DATE: January 31, 1995 SUBJECT: INCOME TAX ACT Contributions to Registered Retirement Savings Plan REFERENCE: REFERENCE:Subsections 146(5) and (5.1) (also sections 60.01 and 204.1 to 204.3 and the definition of “disposition” in section 54; subsections 104(10.2), (27) and (27.1), 146(1), (2), (3), (6.1), (8.2), (8.21) and (8.3), 146.3(5.1), 147.1(1), 147.3(13.1) and 152(6); and paragraphs
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NO.: IT-201R2 DATE: February 12, 1996 SUBJECT: INCOME TAX ACT Foreign Tax Credit — Trust and Beneficiaries REFERENCE: Subsections 104(22) to (22.4) (also section 126; subsections 20(11) and (12), and 104(13) and (14); and the definitions of “business-income tax” and “non-business-income tax” in subsection 126(7) of the Income Tax Act) Application This bulletin cancels and replaces Interpretation Bulletin
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NO: IT-243R4 DATE: February 12, 1996 SUBJECT: INCOME TAX ACT Dividend Refund to Private Corporations REFERENCE: Section 129 (also sections 51, 84, 85.1, 86, 87, 88, 105, 123.2, 125, 150, and 157; subsections 12(10.2), 15(3), 85(1), 104(13) and (14), 126(1) and (2), 161(2), 186(2), 256(2), and 260(7); the definitions of “designated property” and “private corporation” in
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