Section 128.1

Subsection 128.1(1) - Immigration

Administrative Policy

17 June 2014 External T.I. 2013-0506731E5 - Immigration

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Tax Topics - General Concepts - Payment & Receipt note satisfied dividend 77
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) dividend not recognized until paid 166

5 December 2013 External T.I. 2013-0485661E5 - U.K. ISA held by a temporary resident of Canada

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Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(4) - Paragraph 128.1(4)(b) UK ISA held while temporary Canadian resident 84

1999 APFF Round Table, Q. 1 (No. 9M19190)

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Articles

Jack Bernstein, "Impact of Canada's Draft Tax Legislation on Taxpayer Migration", Tax Profile, Vol. 5, No. 30, February 1999, p. 341.

Jack Bernstein, "A Guide for the Emigrating Canadian Resident", 1993 Corporate Management Tax Conference Report, c. 12.

Lanthier, "Corporate Immigration, Emigration, and Continuance", 1993 Corporate Management Tax Conference Report, c. 4.

Richards, "Exit Tax: Corporate Emigration and a Continuance", Canadian Current Tax, August, 1993, p. J13.

Flatters, "Proposed Amendments Relating to Corporate Continuance and Residence", 1993 Canadian Tax Journal, No. 3, p. 567.

Paragraph 128.1(1)(b)

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(16.1) 142
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

30 September 2011 Internal T.I. 2011-0402871I7 - Taxation of accrued interest on immigration

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30 October 2000 External T.I. 2000-0013255 - PRODUCT ISSUED BY FOREIGN INSURER

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Paragraph 128.1(1)(c)

See Also

Landbouwbedrijf Backx B.V. v. The Queen, 2018 TCC 142

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) the central management and control of a B.V. with a sole Dutch director was in Canada 303
Tax Topics - Treaties - Income Tax Conventions - Article 4 Netherlands corporation with central management and control in Canada was not resident in the Netherlands for Treaty purposes 361

Paragraph 128.1(1)(c.1)

Articles

Ron Choudhury, Neil Gurmukh, "Tax Issues on Immigration to Canada", Tax Topics (Wolters Kluwer), No. 2323, 15 September 2016, p. 1

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Paragraph 128.1(1)(d)

Articles

Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24

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Subsection 128.1(4) - Emigration

Administrative Policy

May 1999 CALU Conference No. 9908430 Q. 12

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5 November 1996 T.I. 963459 (C.T.O. "Disposition of a Life Insurance Policy - Emigration")

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Articles

Firoz Talakshi, Patrick A. Jackman, "Corporate Migration: A Comparison of Canadian and US Income Tax Rules", 2001 Conference Report.

Cindy Rajan, "Are You Sure You Want To Leave Canada? The New Taxpayer Migration Rules", Personal Tax Planning, 1999 Canadian Tax Journal, Vol. 47, No. 5, p. 1342.

Lee, "Dear Departures", CA Magazine, November 1997, p. 26.

Parks, "New Departure Tax Rules and Related Proposals Create Problems", International Tax Planning, Vol. VI, No. 1, 1997, p. 373.

Couzin, "Departure Tax - Individuals", Bureau for International Fiscal Documentation, Vol. 49, No. 11, p. 532.

Bowman, "Sophisticated Estate-Planning Techniques: Cross-Border Dimensions", 1993 Conference Report, c. 38.

Paragraph 128.1(4)(b)

Administrative Policy

13 September 2012 CICA Roundtable Q. 7, 2012-0453111C6 - CICA Conference Q7 - Alter ego trust

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5 December 2013 External T.I. 2013-0485661E5 - U.K. ISA held by a temporary resident of Canada

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Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) step-up of shares in UK ISA 87

21 April 2015 External T.I. 2013-0494251E5 - 128.1(4) and Part XIII tax on future payments

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(v) client list utilization payments to U.S. resident 133
Tax Topics - Treaties - Income Tax Conventions - Article 12 client list utilization payments to U.S. resident 172

Subsection 128.1(6) - Returning former resident

Paragraph 128.1(6)(c)

Administrative Policy

30 July 2015 External T.I. 2013-0494871E5 - Paragraph 128.1(6)(c)

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Subsection 128.1(8) - Post-emigration loss

Administrative Policy

24 October 2013 External T.I. 2013-0486321E5 - Former taxable Canadian property and 128.1(8).

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Subsection 128.1(10) - Definitions

excluded right or interest

(c)

Administrative Policy

26 February 2014 External T.I. 2013-0487961E5 - Excluded Right or Interest

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Tax Topics - Treaties - Income Tax Conventions - Article 15 apportionment of stock option benefits based on situs of employment during vesting period 205