Marin v. The Queen, 2022 TCC 49 -- summary under Non-Business-Income Tax
Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Taxtaxes for which FTC accorded must be imposed on the income which generates the Canadian taxes from which the credit is claimed
The taxpayer, a Canadian resident, was generally subject to French income tax on the rental income from a French property to the extent of his...
Words and Phrases
for| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | may-be-taxed language does not confer an exclusive right to tax | 195 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned | 193 |
| Tax Topics - Treaties - Income Tax Conventions - Article 24 | Art. 23 of French Treaty inapplicable where income of a particular taxation year was not otherwise taxed twice | 246 |