Administrative Policy
16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise
During peak season, Canco, which transports passengers to destinations inside and outside Canada, is supplied planes and non-resident pilots and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | application of Sutcliffe/Price allocation approach were s. 115(3) not applicable | 150 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(4) | non-resident's provision of crew and aircraft to Canadian airline | 150 |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | non-resident's provision of crew and aircraft to Canadian airline | 109 |
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | Reg. 102 withholding or waiver notwithstanding Treaty exemption | 166 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | U.K company's provision of crew to Canadian airline/Reg. 102 withholding or waiver notwithstanding Treaty exemption | 291 |