Cases
Cardinal Meat Specialists Ltd. v. Devereux, 92 DTC 6357 (Ont CA)
The respondent, which failed to withhold income tax on a payment to the appellant, was entitled under s. 215(6) to recover from the respondent the...
See Also
3792391 Canada Inc. v. The King, 2023 TCC 37 (Informal Procedure)
The taxpayer was assessed under s. 215(6) for failure to withhold and remit Part XIII tax on rents paid by it in its 2011 to 2016 taxation years...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 227 - Subsection 227(8) | taxpayer failed to establish a due diligence defence | 281 |
Solomon v. The Queen, 2007 DTC 1715, 2007 TCC 654 (Informal Procedure)
After noting that the University of Waterloo and Human Resources and Development Canada had failed to withhold Part XIII tax on pension income and...
Havlik Enterprises Ltd. v. MNR, 89 DTC 159, [1989] 1 CTC 2262 (TCC)
Sales contracts which the Canadian taxpayer ("Havlik") entered into with a Chinese supplier required Havlik to obtain irrevocable letters of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | 100 | |
| Tax Topics - Income Tax Act - Section 215 - Subsection 215(2) | meaning of "or otherwise" | 67 |
Administrative Policy
2013 Ruling 2013-0488291R3 - Reorganization of Corporations - Rollover
Background
Pubco (a Canadian public company) wishes to spin-off Canco and Forco1 (a foreign affiliate) to its shareholders without incurring the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | no ruling on price adjustment clause | 157 |
| Tax Topics - Income Tax Act - Section 52 - Subsection 52(2) | taxable dividend spin-off of thinly capitalized sub | 299 |
16 November 2011 External T.I. 2011-0419191E5 - Foreign Intermediaries & Canadian Owners
Where a foreign financial intermediary ("FFI") has represented to a Canadian financial institution ("CFI") that the beneficial owners of...