Section 110.5 - Additions for foreign tax deductions

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) amalgamation-equivalency policy 323

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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....

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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.