Subsection 81(1) - Amounts not included in income
Paragraph 81(1)(a) - Statutory exemptions
Cases
The Queen v. AEL Microtel Ltd., 86 DTC 6348, [1986] 2 CTC 108 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) | 78 |
See Also
Lapierre v. The Queen, 2019 TCC 18
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 8900 - Subsection 8900(1) - Paragraph 8900(1)(b) | UN-authorized agency was not a UN agency | 114 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(iii) | a Canadian resident working for a UN-authorized agency in Afghanistan was not exempted | 101 |
Administrative Policy
26 August 2015 External T.I. 2015-0564171E5 F - Paiements d'un RPAC à un Indien
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| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.1) | procedure for reduced withholding on pension distributions to status Indian | 187 |
9 April 2013 External T.I. 2012-0461051E5 F - Employee of an international organization
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| Tax Topics - Income Tax Regulations - Regulation 8900 - Subsection 8900(1) - Paragraph 8900(1)(b) | organization was not a specialized agency related to the UN | 106 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) | credit for local taxes imposed on salary of Canadian resident working for an international organization | 231 |
Paragraph 81(1)(c) - Ship or aircraft of non-residents
Cases
Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 202 | |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | deduction of head office expenses | 131 |
Administrative Policy
24 December 2015 Internal T.I. 2014-0560831I7 - International shipping
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Shipping | lease includes time charter | 65 |
16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise
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| 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 | 140 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(4) | non-resident's provision of crew and aircraft to Canadian airline | 140 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Traffic | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | Reg. 102 withholding or waiver notwithstanding Treaty exemption | 162 |
| 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 | 285 |
4 June 1996 T.I. 96 1114
4 May 1995 T.I. 951182 (C.T.O. "Shipping Income - Residents of Greece")
June 1992 Hong Kong Seminar (May 1993 Access Letter, p. 227)
92 C.M.TC - Q.6
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (b) | internationl ship | 18 |
2 July 1991 T.I. (Tax Window, No. 5, p. 15, ¶1326)
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| Tax Topics - Income Tax Act - Section 250 - Subsection 250(6) | 2 | |
| Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(1) | 49 |
Articles
Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Shipping | 82 | |
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(6) | 305 |
Owen, "Tax Issues in International Shipping", 1993 Canadian Tax Journal, Vol. 41, No. 4, p. 724.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(6) | 0 |
Lang, "Taxation of International Aviation: A Canadian Perspective", 1992 Canadian Tax Journal, No. 4, p. 881.
Paragraph 81(1)(d) - Service pension, allowance or compensation
Paragraph 81(1)(e) - War pensions
Paragraph 81(1)(g.1) - Income from personal injury award property
Administrative Policy
28 January 1992 Memorandum (Tax Window, No. 16, p. 17, ¶1723)
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | 52 |
Paragraph 81(1)(h) - Social assistance
See Also
Administrative Policy
Subsection 81(2) - M.L.A.‘s expense allowance
Administrative Policy
83 C.P.T.J. - Q.24
Subsection 81(3) - Municipal officers’ expense allowance
Cases
Bellrose v. Canada, 2012 DTC 5068 [at 6922], 2012 FCA 67
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Administrative Policy
Subsection 81(3.1)
Administrative Policy
S2-F3-C2 - Benefits and Allowances Received from Employment
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Subsection 81(4)
Administrative Policy
15 August 2012 External T.I. 2012-0444461E5 F - Pompiers volontaires
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| Tax Topics - Income Tax Act - Section 118.06 - Subsection 118.06(1) | not a “volunteer” if paid more than a minimal amount or minimum hours are required | 220 |