Administrative Policy
24 July 2014 External T.I. 2014-0522861E5 - Section 110.5 and provincial FTC
May the income inclusions under s. 110.5 and the resulting credit under s. 126(1) be increased to the point that no foreign tax credit is...
7 February 2014 Internal T.I. 2013-0512601I7 - Clarification of 2013-0481151I7
In "clarifying" 2013-0481151I7 (immediately below), CRA stated:
In that letter, we stated that an addition to income under section 110.5… is a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | 110.5 addition not a permissible 84-1 adjustment | 129 |
16 July 2013 Internal T.I. 2013-0481151I7 - Application of 152(4)(b)(iv) and 110.5
Respecting whether s. 152(4)(b)(iv) would allow an assessment to be issued beyond the normal reassessment period in response to the taxpayer's...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | s. 110.5 addition | 79 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iv) | 217 |
18 December 2012 Internal T.I. 2012-0461651I7 - Foreign Tax Credits - s. 126 vs. s. 110.5
Canco realized deductible losses on FX hedging instruments due to the strengthening of the U.S. dollar. Accordingly, it engaged in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | amalgamation-equivalency policy | 323 |
S5-F2-C1 - Foreign Tax Credit
[T]he additional foreign taxes that are used in the year (in the form of an increase to the foreign tax credit for the year by means of section...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | Canadian legal principles applied to "agency" | 57 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | apportionment based on where employee is physically present while performing duties | 46 |
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) | 523 | |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | 444 | |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(2) | 95 | |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(4.1) | 36 | |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax | 71 | |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 114 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) | 271 | |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(3) | 121 |
9 December 2010 Internal T.I. 2010-0379801I7 - Additions to taxable income to utilize FTCs
After the normal reassessment period for its 2005 taxation year had expired, the company submitted a request for an addition to its 2005 taxable...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iv) | 284 |
29 March 2004 External T.I. 2003-0040581E5 - Section 110.5 and Foreign Tax Credit
A Canadian corporation realized a gain on the sale of real property situated in the U.S. for Canadian income tax purposes in year 1 but for U.S....
IT-270R2 "Foreign Tax Credit" under "Addition to Taxable Income"
Articles
Loveland, "Acquisition of a U.S. Business by Canadians: A Canadian Perspective", 1991 Corporate Management Tax Conference Report, c. 11
Discussion of planning opportunities respecting s. 110.5.