See Also
Antle v. The Queen, 2009 DTC 1305, 2009 TCC 465, aff'd 2010 DTC 5172 [at 7304], 2010 FCA 280
After finding against the taxpayer on other grounds, Campbell Miller, J. found that s. 250(5) would not cause a Barbados trust, that was intended...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | interjection of Barbados trust defeated policy | 179 |
Administrative Policy
24 May 2018 External T.I. 2017-0710641E5 - Interest Charge Domestic International Sales Corp
In the course of confirming that an “Interest Charge Domestic International Sales Corporation, would qualify as a resident of the U.S. for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(11.2) | U.S. IC-DISC is “resident” of the U.S. for Treaty purposes as the U.S. asserts its jurisdiction to tax and grants benefits only on continued meeting of conditions | 395 |
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Exempt Earnings - Paragraph (d) | CMC of FA must be in the DTC and it must be liable to tax therein (albeit, may be conditionally exempted) | 233 |
S5-F1-C1 - Determining an Individual’s Residence Status
Where subsection 250(5) applies, an individual will be deemed to be a non-resident of Canada for all purposes of the Act (that is, the individual...
3 November 2008 External T.I. 2008-0278431E5 F - Déménagement hors Canada du siège soc. de société
In the context of a general discussion of consequences where there was an acquisition of control of a corporation incorporated in Canada in 2005,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | OECD Commentary informs allocation of sales through non-resident office to Cdn manufacturing operation | 172 |
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Investment Tax Credit - Paragraph (a.1) | ITC potentially available to a non-resident corporation carrying on business in Canada | 97 |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(b) | s. 4(1)(b) requires allocation between Canada and another country on basis of relative profit contribution | 172 |
8 July 2002 External T.I. 2002-0136615 F - Par. 250(5) - Déclaration de revenus
CCRA indicated that an individual who is deemed to be a non-resident of Canada by s. 250(5) is not required to declare world income in the...
27 June 1994 External T.I. 9406005 - CORPORATE STATUS OF A DELAWARE LLC (4093-U5-100-4)
If a Delaware limited liability company having its central management and central in Canada is treated as a partnership rather than a corporation...