Section 181.3

Subsection 181.3(1) - Taxable capital employed in Canada of financial institution

See Also

Royal Trustco v. The Queen, 2001 DTC 52 (TCC)

The taxpayer, and a partnership of which it was a member, leased equipment. Sarchuk T.C.J. accepted evidence that upon execution of the leases the...

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Manufacturers Life Insurance Co. v. The Queen, 2000 DTC 1600 (TCC)

In the financial statements of the taxpayer (a life insurance company) that were prepared in accordance with the OSFI rules, gains or losses...

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Administrative Policy

Revenue Canada Round Table TEI, 16 May 1994, Q. 6-3 (C.T.O "Whether Lease Receivable Constitutes Tangible Property")

Leased receivables do not constitute tangible property.

7 June 1990 T.I. (November 1990 Access Letter, ¶1546)

Property which is acquired and held in the ordinary course of a particular business is considered to be "used in Canada" for purposes of the...

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1 June 1990 T.I. (November 1990 Access Letter, ¶1545)

Cash on hand, term deposits, marketable securities, funds on deposit and other financial institutions, accounts receivable, and mortgages or notes...

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Subsection 181.3(3) - Capital of financial institution

See Also

Manufacturers Life Insurance Co. v. The Queen, 2000 DTC 1600 (TCC)

In the financial statements of the taxpayer (a life insurance company) that were prepared in accordance with the OSFI rules, gains or losses...

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Administrative Policy

18 July 1991 T.I. (Tax Window, No. 5, p. 18, ¶1330)

Non-equity shares of a credit union governed by the Credit Union Incorporation Act (B.C.) constitute capital for large corporations tax purposes...

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Paragraph 181.3(3)(d)

Administrative Policy

30 September 1997 Internal T.I. 9703217 F - DEFINITION DU MOT "SURPLUS" SELON SON SENS COMMUN

The "head office" account of a Canadian branch of a non-resident insurer is included as "any other surpluses" under s. 181.3(3)(d)(ii) to the...

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Subsection 181.3(4) - Investment allowance of financial institution

Paragraph 181.3(4)(a)

Administrative Policy

12 June 1990 T.I. (November 1990 Access Letter, ¶1547)

Where the financial institution has made a contribution of capital to one of its subsidiaries which is recorded as contributed surplus, the amount...

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