Regulation 102

Administrative Policy

2015 Ruling 2014-0542411R3 - Carrying on business in Canada and PE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 5 PE in Canada of ForCo avoided through seconding employees to its Cdn sister and meeting in Canada up to 90 days annually only offsite 513
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) seconded employees respected as employees notwithstanding their payroll is paid by (and reimbursed to) ForCo 57
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) no mark-up on cross-border payroll reimbursement represented to accord with s. 247 101

Subsection 102(1)

Administrative Policy

27 November 2017 External T.I. 2017-0731441E5 - Interchange Canada and Business Number

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) a non-resident corporation is carrying on business in Canada by virtue of being the legal employer of an employee seconded to Canada 163
Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) NR corp carrying on business in Canada by virtue of being reimbursed for payroll costs of seconded employee 130
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) salary reimbursement payments made to seconding NR employer subject to withholding 107

4 February 2016 Internal T.I. 2015-0620821I7 F - Withholding of income tax at source

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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 Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) non-resident's provision of crew and aircraft to Canadian airline 103
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

22 March 2012 Internal T.I. 2012-0436311I7 - payroll withholdings by non-resident employer

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 December 1999 Miscellaneous 1999-0007810 - Application of subsection 17(2)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"

Articles

Anu Nijhawan, "Source Withholdings: Non Resident Employees 'Visiting' Canada", Taxation of Executive Compensation and Retirement, Vol. 15, No. 9, May 2004, p. 412.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1.1) 0

Forms

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Navigation