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 | |
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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 | |
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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 | |
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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 | |
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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 | |
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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.