Administrative Policy
3 November 2021 CTF Roundtable Q. 14, 2021-0911951C6 - Failure to properly file a T1135
The T1135 form and related disclosure stated that specified foreign property “does not include … a share of the capital stock or indebtedness...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property - Paragraph (k) | CRA will entertain penalty and interest waiver where taxpayer was misled by Form as to the narrowness of FA exclusion | 208 |
18 February 2013 External T.I. 2012-0467121E5 - Associated corporations, Debt Forgiveness
Husband and Wife own 51% and 49% of the shares of a non-resident corporation (ForeignCo) and 49% and 51% of the shares of CanadaCo. The two...
15 July 2011 Internal T.I. 2010-0388621I7 - Entity Classification - Liechtenstein Anstalt
A Liechtenstein anstalt did not issue shares within the meaning of s. 248(1), as there was only one beneficiary. However, a division of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | anstalt a corp | 98 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share | division of capital not necessary for "shares" | 136 |
2004 Ruling 2004-0103111R3 - Foreign affiliates; indirect payment
Ruling that a U.S. LLC would be considered a corporation, that the ownership interest of a member would be considered shares, and that...
5 October 2001 Comfort Letter 2001 1005B
Proposed amendment to deem for purposes of s. 95(2)(a) a non-resident corporation to be a foreign affiliate of a particular corporation resident...
27 June 1994 External T.I. 9406005 - CORPORATE STATUS OF A DELAWARE LLC (4093-U5-100-4)
If a Delaware limited liability company is treated as a partnership rather than a corporation for purposes of the Internal Revenue Code, with the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | 29 | |
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(5) | 96 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 67 |
16 December 1993 T.I. (C.T.O. "6363-1 Foreign Affiliate Deemed Active Business Income")
A Wyoming limited liability corporation that indirectly was owned 50% by each of two Canadian corporations dealing at arm's length with each other...
93 C.M.TC - Q. 12
The limited liability companies for the two states that RC has reviewed (Wyoming and Florida) are considered to be corporations rather than...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | 23 |
December 1992 B.C. Tax Executives Institute Round Table, Q.14 (October 1993 Access Letter, p. 482)
A foreign corporation is a foreign affiliate of a partnership of corporations, and not of the corporate partners.
88 C.R. - Q.11
A corporation resident in a listed country all of whose shares are "owned" by a partnership is not a foreign affiliate of a 30% partner, because...