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Income Tax Folio S5-F1-C1, Determining an Individual’s Residence Status

Series 5: International and Residency Folio 1: Residency Chapter 1: Determining an Individual’s Residence Status Summary The purpose of this Chapter is to explain the position of the Canada Revenue Agency (CRA) concerning the determination of an individual’s residence status for income tax purposes and the factors to be taken into account in making that determination. […]

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Fundy Settlement v. Canada (2012 SCC 14)

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

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IT262R2- Losses of Non-Residents and Part-Year Residents

NO: IT-262R2 DATE: November 28, 1996 SUBJECT: INCOME TAX ACT Losses of Non-Residents and Part-Year Residents REFERENCE: Section 114, subsection 111(9) and paragraphs 115(1)(c) and 115(1)(e) (also sections 3, 31 and 80 and subsections 2(3), 96(2.1), 111(1), 111(1.1), 111(3) and 111(8)) Application This bulletin cancels and replaces IT-262R dated August 30, 1985. Summary The Income Tax Act contains a system of rules

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IT153R3-Land Developers-Subdivision and Development Costs and Carrying Charges on Land

NO: IT-153R3 DATE: October 7, 1991 SUBJECT: INCOME TAX ACT Land developers – Subdivision and development costs and carrying charges on land REFERENCE: Subsections 18(2), (2.2), (2.3), (2.4), (2.5), (3), (also subsections 10(1), (1.1) and the definition of “specified shareholder” and “business” in subsection 248(1), paragraphs 18(1)(a), 20(1)(c), 53(1)(d.3) and subparagraph 53(1)(e)(xi) of the Income Tax

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IT168R3- Athletes and players employed by football, hockey and similar clubs

NO: IT-168R3 DATE: May 13, 1991 SUBJECT: INCOME TAX ACT Athletes and Players Employed by Football, Hockey and Similar Clubs REFERENCE: Section 6 (subsection 2(3), sections 8, 115 and 212 and paragraphs 18(1)(p) and 125(7)(d) and the definitions of “retirement compensation arrangement” and “salary deferral arrangement” in subsection 248(1)) Application This bulletin cancels and replaces Interpretation

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IT113R4- Benefits to Employees – Stock Options

NO: IT-113R4 DATE: August 7, 1996 SUBJECT: INCOME TAX ACT Benefits to Employees – Stock Options REFERENCE: Section 7 (also subsections 2(3), 5(1), 8(12), 110(1.5), 115(1) and the definition of “Canadian-controlled private corporation” in subsection 125(7), paragraphs 6(1)(a), 53(1)(j) and 110(1)(d) and (d.1), and subparagraph 128.1(4)(b)(vi) of the Income Tax Act; and section 6204 of the

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IT176R2-Taxable Canadian property – Interests in and options on real property and shares

  NO: IT-176R2 DATE: April 23, 1993 SUBJECT: INCOME TAX ACT Taxable Canadian Property – Interests in and Options on Real Property and Shares REFERENCE: Paragraph 115(1)(b) (also subsections 2(3) and 115(3) and paragraph 89(1)(g)) Application This bulletin cancels and replaces Interpretation Bulletin IT-176R dated September 2, 1975. Summary Non-residents are subject to taxation in Canada

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