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Notice of Ways and Means Motion October 2018 – Cross-Border Surplus Stripping Using Partnerships and Trusts

Cross-Border Surplus Stripping Using Partnerships and Trusts   Budget 2018 The Income Tax Act contains a rule (section 212.1) that is intended to prevent a non-resident shareholder from entering into transactions to extract free of tax (or “strip”) a Canadian corporation’s surplus in excess of the PUC of its shares, or to artificially increase the […]

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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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IT155R3-Exemption from non-resident tax on interest payable on certain bonds, debentures, notes, hypothecs or similar objects

NO.: IT-155R3 DATE: June 16, 1989 SUBJECT: INCOME TAX ACT Exemption from Non-Resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations REFERENCE: Clause 212(1)(b)(ii)(C) (also subsection 212(15)) Application This bulletin replaces and cancels Interpretation Bulletin IT-155R2 dated May 4, 1984. Current revisions are designated by vertical lines. Summary Paragraph 212(1)(b) provides for

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Income Tax Folio S3-F2-C1, Capital Dividends

Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the

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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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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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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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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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