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" The Supreme Court of Canada found in Savage, 83 DTC 5409 and Nowegijick, 83 DTC 5041 that the words "in respect of" are "... of the widest possible scope. ...

Cette allocation est payée sous forme d'avance mensuelle représentant un montant de XXXXXXXXXX francs belges, soit environ XXXXXXXXXX $ canadiens. 4. ...

Jim Wilson Section Chief Business, Property & Employment Section II Business and Publications Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

Subsection 200(1) of the Regulations states that "Every person who makes a payment described in subsection 153(1) of the Act [...] shall make an information return in prescribed form in respect of such payment.... ...

Our Comments Assistance for Tuition/Training Costs As indicated in our memorandum of March 1, 1999, (file # 990470) paragraph 56(1)(n) of the Act requires the inclusion into income of certain scholarships, bursaries and fellowships, with a $500 exemption. ...

ITRD has generally accepted that share appreciation rights (“SAR”) plans of the type described in ATR-45 – “Share Appreciation Rights Plan” would not be SDAs (“ATR-45 SAR Plans”). ...

13 November 2020 Internal T.I. 2020-0864831I7- Equity award plan and recharge agreement Unedited CRA Tags 7(3)(b), 248(1) “salary deferral arrangement”, 20(1)(oo), 15(1), 212(2)(a), 214(3)(a), 246(1) * Principal Issues: 1. ...

In particular, Article IV(1)(a) defines the term “resident of a Contracting State” as follows: “For the purposes of this Agreement, the term “resident of a Contracting State” means: (a) any person who, under the laws of that State, is liable to tax therein by reason of that person’s domicile, residence, place of management or any other criterion of a similar nature, but does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein; and” [emphasis added] It has been our long-standing position, as stated in the Income Tax Technical News 35, Treaty Residence – Resident of Convenience, dated February 26, 2007 (“ITTN-35”), that, to be considered “liable to tax” for the purposes of the residence article of Canada’s income tax treaties, a person must be subject to the most comprehensive form of taxation as exists in the relevant contracting state. ...

| Revenue Québec (revenuquebec.ca) ...

Cette allocation est imposable à moins de faire partie des exceptions énumérées aux sous-alinéas 6(1)b)(i) à (ix) de la Loi de l'impôt sur le revenu (ci-après la «Loi »). ...