Cases
The Queen v. Albino, 94 DTC 6071, [1994] 1 CTC 205 (FCTD)
In 1973, the taxpayer agreed to participate in an "incentive performance plan" of his employer under which the taxpayer was granted "share...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | 145 | |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 57 |
Administrative Policy
20 March 2015 External T.I. 2014-0534301E5 - Canadian Withholding Tax on Retiring Allowance
A lump sum payment in respect of a loss of employment is made by Canco to a non-resident of Canada (the "Taxpayer") who had been seconded to a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(e) - Subparagraph 115(2)(e)(i) | retiring allowance paid to non-resident for loss of non-resident employment | 56 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | retiring allowance paid to French individual for loss of non-resident employment | 73 |
| Tax Topics - Treaties - Income Tax Conventions - Article 22 | retiring allowance paid to French individual for loss of non-resident employment | 73 |
19 March 2002 External T.I. 2002-0120785 F - Allocation de retraite - 212(13)(d)
An individual worked for 10 years in Canada for a Canadian corporation, then ceased to be resident and worked the next 12 years for a sister U.S....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 215 - Subsection 215(2) | s. 215(2) applicable to retiring allowance paid by US employer where it invoiced the sister Canadian corporation, as the predecessor employer, therefor | 177 |