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Old website (cra-arc.gc.ca)

RRSPs and Other Registered Plans for Retirement

Qualifying retirement plan – for purposes of the Canada-U.S. tax convention, a United States qualifying retirement plan is a plan that is generally exempt from income tax in the U.S. and is operated primarily to provide pension or retirement benefits. ... For a complete list of qualifying U.S. retirement plans, go to Protocol Amending the Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital and see paragraph 10. ... However, Canada has entered into income tax conventions or agreements, commonly known as tax treaties, with many countries that allow a deduction on your Canadian income tax and benefit return for some of those contributions. ...
Archived CRA website

ARCHIVED - Previous-year tax packages - Non-residents and deemed residents of Canada - 1995

Note Under proposed changes to the Canada-United States Tax Convention, starting in 1996, you will no longer be taxed in Canada on your U.S. social security benefits. ... Note You cannot deduct contributions you made to pension plans in other countries, with two exceptions: under the Canada-France Income Tax Convention and the Canada-Netherlands Income Tax Convention, you may be able to deduct, under certain circumstances, contributions to a pension plan. ...
Current CRA website

RRSPs and Other Registered Plans for Retirement

Qualifying retirement plan – for purposes of the Canada-U.S. tax convention, a United States qualifying retirement plan is a plan that is generally exempt from income tax in the U.S. and is operated primarily to provide pension or retirement benefits. ... For a complete list of qualifying U.S. retirement plans, go to Protocol Amending the Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital and see paragraph 10. ... However, Canada has entered into income tax conventions or agreements, commonly known as tax treaties, with many countries that allow a deduction on your Canadian income tax and benefit return for some of those contributions. ...
Current CRA website

Income Tax Audit Manual

These expenses could include such items as promotion and entertainment outlays and the payment of the expenses of the shareholder-employee's spouse or common-law partner at a business convention. Go to: Income Tax Folio S2-F3-C2, Benefits and Allowances Received from Employment Income Tax Interpretation Bulletin IT131R2, Convention expenses; paragraphs 7 and 8 are cancelled by Income Tax Folio S2-F3-C2, Benefits and Allowances Received from Employment If an amount is treated by a corporation as wages to a shareholder-employee, regardless of the actual payee of the amount, the CRA will consider it to be wages to that employee. ... When a non-resident makes a transfer of property under subsection 85(1) of the ITA, consult the TSO International Audit Section to ensure the provisions of the ITA (for example, section 116 of the ITA- Clearance Certificate) and Income Tax Convention are considered. ...
Current CRA website

Income Tax Audit Manual

Benefits related to the corporation's business activities Benefits made to a shareholder who is also an officer or employee, which relate to the business activities of the corporation or can reasonably be viewed as additional salary, will be taxed under paragraph 6(1)(a).These expenses could include such items as promotion and entertainment outlays and the payment of the expenses of the shareholder-employee's spouse or common-law partner at a business convention. Go to: Income Tax Folio S2-F3-C2, Benefits and Allowances Received from Employment Income Tax Interpretation Bulletin IT131R2, Convention expenses; paragraphs 7 and 8 are cancelled by Income Tax Folio S2-F3-C2, Benefits and Allowances Received from Employment If an amount is treated by a corporation as wages to a shareholder-employee, regardless of the actual payee of the amount, the CRA will consider it to be wages to that employee. ... When a non-resident makes a transfer of property under subsection 85(1) of the ITA, consult the TSO International Audit Section to ensure the provisions of the ITA (for example, section 116 of the ITA- Clearance Certificate) and Income Tax Convention are considered. ...
Current CRA website

Information for non-residents and deemed residents of Canada

Note Under proposed changes to the Canada-United States Tax Convention, starting in 1996, you will no longer be taxed in Canada on your U.S. social security benefits. ... Note You cannot deduct contributions you made to pension plans in other countries, with two exceptions: under the Canada-France Income Tax Convention and the Canada-Netherlands Income Tax Convention, you may be able to deduct, under certain circumstances, contributions to a pension plan. ...
Current CRA website

Info Source

Personal information obtained pertaining to residents of countries with which Canada has Income Tax Conventions may be shared with those taxing authorities by way of an exchange of information under the appropriate treaty provision. ... Personal information obtained about residents of countries with which Canada has Income Tax Conventions may be shared with those taxing authorities by way of an exchange of information under the appropriate treaty provision. ...
Archived CRA website

ARCHIVED - Losses of a Corporation . The Effect that Acquisitions of Control, Amalgamations, and Windings-up have on Their Deductibility . After January 15, 1987

For purposes of the non-arm's length exception to the half-year capital cost allowance convention in subsection 1100(2.2) of the Regulations, the corporation is considered not to be dealing with itself at arm's length. ...
Old website (cra-arc.gc.ca)

TPM-15 - Intra-group services and section 247 of the Income Tax Act

Royalty payment and management fees: Paragraph 4 of Article XII, Royalties, of the technical explanation of the Canada–United States Income Tax Convention indicates that the term royalties does not encompass management fees. ...
Old website (cra-arc.gc.ca)

Code of integrity and professional conduct: How we work

The Constitution of Canada and the principles of responsible government provide the foundation for the role, responsibilities and values of the federal public sector. [1] Constitutional conventions of ministerial responsibility prescribe the appropriate relationships among ministers, parliamentarians, public servants [2] and the public. ...

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