(2)-(14)

Table of Contents

Subsection 212(2) - Tax on dividends

Cases

Placements Serco Ltee v. The Queen, 84 DTC 6098 (FCTD), aff'd 88 DTC 6125 (FCA)

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The Canada Southern Ry. Co. v. The Queen, 82 DTC 6244, [1982] CTC 278 (FCTD), rev'd 86 DTC 6097, [1986] 1 CTC 284 (FCA)

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Administrative Policy

10 February 2011 External T.I. 2010-0387151E5 - Deemed Disposition of Shares by a Non-Resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) potential s. 116(5) withholding not reduced by Pt XIII tax 42

October 1992 Central Region Rulings Directorate Tax Seminar, Q. G (May 1993 Access Letter, p. 230)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 22

20 July 1992 External T.I. 5-921355 -

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4 March 1992 T.I. (December 1992 Access Letter, p. 20, ¶C82-106, Tax Window, No. 17, p. 23, ¶1778)

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4 October 1991 T.I. (Tax Window, No. 10, p. 16, ¶1498)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares 57

Articles

Todd Miller, Ryan Morris, "Canadian Subsidiary Guarantees for Foreign Parent Borrowings", Tax Notes International Vol. 34, No. 1, 5 April 2004, p. 63.

Subsection 212(3) - Interest — definitions

Fully exempt interest

Administrative Policy

2012 Ruling 2011-0431891R3 - XXXXXXXXXX

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Paragraph (a)

Subparagraph (a)(i)

Subparagraph (a)(iii)

See Also

Laval Technopole v. Agence du revenu du Québec, 2018 QCCQ 6352

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Words and Phrases
Crown agency
Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency 184
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(c) municipally influenced companies were agents of the municipality 80

Participating debt interest

Administrative Policy

2016 Ruling 2016-0664041R3 - Participating debt interest - contingent payment

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2016 Ruling 2015-0602711R3 - Interest on Notes to Non-Residents

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) deductible interest on subordinated debt with mandatory insolvency conversion 202

21 January 2015 Internal T.I. 2014-0547431I7 - "Excluded amount" under clause 20(1)(e)(iv.1)(C)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) payment to creditor excluded as based on negotiated estimate of formula approximating share value 318

2014 Ruling 2014-0539791R3 - Paragraph 212(1)(b)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) creditors' approval of CCAA plan of compromise for the debtor trust did not cause them to not deal at arm's length with trust 365
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) creditors' approval of CCAA plan of compromise for the debtor trust did not cause them to not deal at arm's length with trust 188

2014 Ruling 2014-0523691R3 - Non-Viable Contingent Capital

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) non-viable contingent capital sub debt of bank respected as non-participating interest debt 158

2014 Ruling 2013-0514551R3 - Convertible Debentures and Paragraph 212(1)(b)

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26 November 2013 Annual CTF Roundtable, 2013-0509061C6 - Part XIII Tax & Standard Convertible Debentures

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 214 - Subsection 214(8) - Paragraph 214(8)(c) interest and premium on standard convertible debenture not participating 77

18 March 2014 External T.I. 2013-0515631E5 - Criteria for Standard Convertible Debentures

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2013 Ruling 2013-0475701R3 - MIC deemed interest & participating debt interest

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2012 Ruling 2011-0418721R3 - Convertible Notes

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23 May 2013 IFA Round Table, Q. 9

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1 May 2009 IFA Roundtable Q. 12, 2009-0320231C6 F - Convertible Debt Obligations

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 214 - Subsection 214(7) no deemed interest on conversion of traditional convertible debenture 180

Income Tax Technical News, No. 41, 23 December 2009 Under "Convertible Debt", Q. 2

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 214 - Subsection 214(7) convertible premium taints all other interest 53

29 May 2009 External T.I. 2008-0301391E5 - EBITDA

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2006 Ruling 2006-0208001R3 - Post-amble to paragraph 212(1)(b)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) participation based on mutual funds 58

2005 Ruling 2005-0161521R3 - Postamble of 212(1)(b)

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8 January 2003 External T.I. 2002-017313 -

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9 October 2001 External T.I. 2001-009665 -

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22 November 2000 External T.I. 2000-004941 -

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16 May 2000 External T.I. 2000-001101 -

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Articles

Daniel Lang, Larissa Tkachenko, "Withholding Tax Implications of Participating Interest in Convertible Debt", CCH Tax Topics, No. 1916, November 27, 2008, p. 1.

Subsection 212(3.1)

Articles

Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure? ", Canadian Tax Journal, (2016) 64:4, 833-58

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Paragraph 212(3.1)(c)

Administrative Policy

17 November 2015 Roundtable, 2015-0614241C6 - 2015 TEI Liaison Meeting Q.6 - Specified Right

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(c) cross-border notional cash-pooling arrangement produced intermediary debt 93

Articles

Mark Coleman, "Treaty Shopping and Back-to-Back Loan Rules", Power Point Presentation for 28 May 2015 IFA Conference in Calgary.

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Steve Suarez, "Canada Releases Revised Back-to-Back Loan Rules", Tax Notes International, October 27, 2014, p. 357.

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Steve Suarez, "An Analysis of Canada's Latest International Tax Proposals", Tax Notes International, September 29, 2014, p. 1131.

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Subparagraph 212(3.1)(c)(ii)

Articles

Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper

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Paragraph 212(3.1)(d)

Articles

Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper

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Mark Coleman, "Treaty Shopping and Back-to-Back Loan Rules", Power Point Presentation for 28 May 2015 IFA Conference in Calgary.

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Michael N. Kandev, "Canadian Interest Anti-Conduit Rule Soon to Be Law", Tax Notes International, December 15, 2014, p. 1027

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Paragraph 212(3.1)(e)

Articles

Edward A. Heakes, "The Proposed Revisions to Back-to-Back Loan Rules", International Tax Planning (Federated Press), Vol. XIX, No. 4, 2014, p. 1357.

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Steve Suarez, "Canada Releases Revised Back-to-Back Loan Rules", Tax Notes International, October 27, 2014, p. 357.

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Steve Suarez, "An Analysis of Canada's Latest International Tax Proposals", Tax Notes International, September 29, 2014, p. 1131.

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Subsection 212(3.2)

Articles

Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure? ", Canadian Tax Journal, (2016) 64:4, 833-58

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Sabrina Wong, "Bill C-29 Amendments to the Back-to-Back Rules", International Tax, Wolters Kluwer CCH, December 2016, No. 91, p. 5

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Subsection 212(3.21)

Subsection 212(3.3)

Subsection 212(3.4)

Articles

PWC, "Bill C-29 significantly expands back-to-back rules", Tax Insights PWC International Tax Services, Issue 2016-53, 16 November 2016

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Subsection 212(3.5)

Subsection 212(3.6)

Paragraph 212(3.6)(a)

Articles

Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper

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Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32

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Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087

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Sabrina Wong, "Bill C-29 Amendments to the Back-to-Back Rules", International Tax, Wolters Kluwer CCH, December 2016, No. 91, p. 5

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Finance

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Subparagraph 212(3.6)(a)(ii)

Articles

Peter Lee, "The Character Substitution Rules", International Tax (Wolters Kluwer CCH), June 2017, No. 94, p. 10

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.7) 397

Paragraph 212(3.6)(b)

Articles

Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087

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Words and Phrases
royalty

Subsection 212(3.7)

Articles

Peter Lee, "The Character Substitution Rules", International Tax (Wolters Kluwer CCH), June 2017, No. 94, p. 10

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Subsection 212(3.8)

Relevant Funder

Specified Share

Articles

Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper

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Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32

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Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087

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Ultimate Funder

Subsection 212(3.9)

Paragraph 212(3.9)(b)

Articles

Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure? ", Canadian Tax Journal, (2016) 64:4, 833-58

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Subparagraph 212(3.9)(b)(ii)

Articles

Sabrina Wong, "Bill C-29 Amendments to the Back-to-Back Rules", International Tax, Wolters Kluwer CCH, December 2016, No. 91, p. 5

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PWC, "Bill C-29 significantly expands back-to-back rules", Tax Insights PWC International Tax Services, Issue 2016-53, 16 November 2016

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Subsection 212(3.91)

Articles

Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32

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PWC, "Bill C-29 significantly expands back-to-back rules", Tax Insights PWC International Tax Services, Issue 2016-53, 16 November 2016

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Subsection 212(3.92)

Paragraph 212(3.92)(b)

Subparagraph 212(3.92)(b)(ii)

Subsection 212(4)

Paragraph 212(4)(a)

Cases

Windsor Plastic Products Ltd. v. The Queen, 86 DTC 6171, [1986] 1 CTC 331 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) shareholders acting in concert 106

Administrative Policy

30 March 2017 Internal T.I. 2016-0636721I7 - Consent fees and withholdings

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Tax Topics - Income Tax Act - Section 214 - Subsection 214(15) - Paragraph 214(15)(b) whether consent fee was deemed to be interest under s. 212(15)(b) was moot 116
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1) non-resident dealer who attended at Canadian board meetings was rendering services in Canada 168

2011 Ruling 2011-0416891R3 - Fees for Digital Content & Management Services

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Paragraph 212(4)(b)

See Also

Agricultural and Industrial Corporation v. MNR, 91 DTC 1286 (TCC)

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Administrative Policy

IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1989

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Subsection 212(5) - Motion picture films

Cases

MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)

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CBS/Fox Co. v. The Queen, 95 DTC 5631 (FCTD)

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MCA Television Ltd. v. The Queen, 94 DTC 6375 (FCTD)

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MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)

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See Also

Vauban Productions v. The Queen, 79 DTC 5186, [1979] CTC 262 (FCA)

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Administrative Policy

27 March 2018 External T.I. 2017-0715561E5 - Withholding tax on royalties for streamed content

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Section 35 - Subsection 35(1) - Broadcasting Interpretation Act definition of broadcasting not applicable to Treaty interpretation of those words 232
Tax Topics - Treaties - Income Tax Conventions - Article 12 television and broadcasting included digital streaming 330

5 November 2014 External T.I. 2013-0506191E5 - copyright photographs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(vi) payments for photos before incorporation into TV program were exempt 98

1 May 2014 External T.I. 2013-0514291E5 F - Redevances sur une oeœuvre musicale dans un film

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(vi) copyright royalty for music used in film is exempt notwithstanding s. 212(5) exclusion 235

14 December 2011 Internal T.I. 2011-0424221I7 - copyright music

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19 April 2011 External T.I. 2011-0392761E5 - Motion picture films, ITA 212(5)

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19 February 1997 T.I. 961630 [health club videos]

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6 March 1995 Memorandum 942876 (C.T.O. "Video Reproduction Rights")

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 12 27

93 C.R. - Q. 30

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5 January 1993, T.I. (Tax Window, No. 28, p. 8, ¶2404)

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Subsection 212(11) - Payment to beneficiary as income of trust

Administrative Policy

22 December 2016 External T.I. 2015-0608201E5 F - Capital distribution from trust & NR4

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 202 - Regulation 202(1) - Regulation 202(1)(c) all capital distributions made by Canadian-resident trusts to a non-resident beneficiaries must be reported on NR4s 134

18 November 2011 External T.I. 2011-0422441E5 - Capital dividend paid to a Non-Resident

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(c) redistribution of capital dividend subject to Part XIII tax 149

9 October 2009 APFF Roundtable Q. 5, 2009-0327001C6 F - Succession canadienne - dividende en capital

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(c) allocation of capital dividend between estate duties and NR distribution 125

17 July 2003 External T.I. 2003-0020695 - Distribution from Trust

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20 October 1997 T.I. 971526

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12 April 1995 External T.I. 5-941713 -

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Alberta Chartered Accountants Round Table, 2 May 1994, Q. 8, 940956 (C.T.O. "Capital Amount Paid by Trust to Non-Resident (8192)")

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22 February 1994 External T.I. 5-932954 -

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IT-465R "Non-Resident Beneficiaries of Trusts" 19 September 1985

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Subsection 212(13) - Rent and other payments

Paragraph 212(13)(a)

Administrative Policy

14 November 1997 Memorandum 971822

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Subsection 212(13.1) - Application of Part XIII tax where payer or payee is a partnership

Paragraph 212(13.1)(a)

See Also

The Queen v. Williams, 90 DTC 6399 (FCA), rev'd 92 DTC 6320 (SCC)

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Twock v. Estate Duty Commissioners, [1988] 1 WLR 1035 (PC)

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Administrative Policy

13 July 2018 Internal T.I. 2017-0713301I7 - Assumption of accrued interest

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) the covenant of the assuming debtor to pay accrued interest on a debt assumption was a payment in kind subject to Part XIII tax 323

25 May 2004 Miscellaneous 2003-0039231E5 - Paragraph 212(13.1)(a)

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7 May 2004 Miscellaneous 2004-0072131C6 - IFA Round Table 2004 Q.1 - 212(13.1)(a)

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25 February 1991 External T.I. 903237

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6 February 1990 T.I. (July 1990 Access Letter, ¶1336)

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12 November 1980 External T.I. RCT-0246

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3 November 1980 Internal T.I. RCT-0247

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Articles

Gregory Wylie, "Canada Revenue Agency Comments on Cross-Border Transactions", Tax Notes International, 7 June 2004, p. 991

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J. S. Peterson, "Canadian Taxation of Non-Residents", 1974 Conference Report (Canadian Tax Foundation), p. 262

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Paragraph 212(13.1)(b)

Cases

Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22

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Words and Phrases
credit payment
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt replacement with different currency note 58
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) 148

Administrative Policy

27 March 2013 External T.I. 2012-0450491E5 - Election under s. 216

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 216 - Subsection 216(4) tenant not generally expected to withhold 139

30 October 1997 External T.I. 9716735 - : Taxation of Non-Resident Partners

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Articles

J. S. Peterson, "Canadian Taxation of Non-Residents", 1974 Conference Report (Canadian Tax Foundation), p. 262

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Subsection 212(13.2) - Application of Part XIII tax — non-resident operates in Canada

See Also

Eastern Success Co Ltd In It's Capacity as Trustee Of The Easter Law Trust v. The Queen, 2004 DTC 3521, 2004 TCC 689

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Administrative Policy

24 February 2000 Internal T.I. 1999-001425

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1996 Corporate Management Tax Conference Round Table, Q. 8

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Subsection 212(13.3) - Application of Part XIII to authorized foreign bank

Administrative Policy

13 July 2001 Comfort Letter No. 20010713

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Subsection 212(14)

Administrative Policy

IC 77-16R4 "Non-Resident Income Tax" under "Certificate of Exemption - 212(14)"