Section 110.5

Administrative Policy

24 July 2014 External T.I. 2014-0522861E5 - Section 110.5 and provincial FTC

May the income inclusions under s. 110.5 and the resulting credit under s. 126(1) be increased to the point that no foreign tax credit is...

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7 February 2014 Internal T.I. 2013-0512601I7 - Clarification of 2013-0481151I7

In "clarifying" 2013-0481151I7 (immediately below), CRA stated:

In that letter, we stated that an addition to income under section 110.5… is a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 110.5 addition not a permissible 84-1 adjustment 129

16 July 2013 Internal T.I. 2013-0481151I7 - Application of 152(4)(b)(iv) and 110.5

Respecting whether s. 152(4)(b)(iv) would allow an assessment to be issued beyond the normal reassessment period in response to the taxpayer's...

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18 December 2012 Internal T.I. 2012-0461651I7 - Foreign Tax Credits - s. 126 vs. s. 110.5

Canco realized deductible losses on FX hedging instruments due to the strengthening of the U.S. dollar. Accordingly, it engaged in the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) amalgamation-equivalency policy 323

9 December 2010 Internal T.I. 2010-0379801I7 - Additions to taxable income to utilize FTCs

After the normal reassessment period for its 2005 taxation year had expired, the company submitted a request for an addition to its 2005 taxable...

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29 March 2004 External T.I. 2003-0040581E5 - Section 110.5 and Foreign Tax Credit

A Canadian corporation realized a gain on the sale of real property situated in the U.S. for Canadian income tax purposes in year 1 but for U.S....

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IT-270R2 "Foreign Tax Credit" under "Addition to Taxable Income"

Articles

Loveland, "Acquisition of a U.S. Business by Canadians: A Canadian Perspective", 1991 Corporate Management Tax Conference Report, c. 11

Discussion of planning opportunities respecting s. 110.5.