(a)-(c)

Paragraph 212(1)(a) - Management fee

Cases

Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085 (FCTD), aff'd 91 DTC 5543 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 212(1)(b) - Interest

Cases

The Queen v. Immobiliare Canada Ltd., 77 DTC 5332, [1977] CTC 481 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) sale of bond with accrued interest did not satisfy interest 170
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 89
Tax Topics - Income Tax Act - Section 76 103

See Also

Kinguk Trawl Inc. v. The Queen, 2002 DTC 1399 (TCC), rev'd 2003 DTC, 2003 FCA 85

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wenger's Ltd. v. MNR, 92 DTC 2132 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Havlik Enterprises Ltd. v. MNR, 89 DTC 159 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Inland Revenue Commissioners v. Oswald, [1945] A.C. 360, 26 TC 435

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Holder v. C.I.R., [1932] A.C. 624 (HL)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2018 Ruling 2017-0732001R3 - XXXXXXXXXX

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest which the issuer can elect not to pay was treated as non-deductible 170

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
novation
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(a) withholding when debt of Canadian partnership assumed by sub 154

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest interest paid on limited recourse debt to the extent of available debtor was not participating debt interest 231
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

16 April 2014 External T.I. 2014-0525071E5 - Part XIII tax on interest payments

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 January 2008 External T.I. 2007-0241391E5 - Withholding tax on payments made by a guarantor

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 March 2007 Internal T.I. 2006-0214291I7 - Part XIII withholding tax

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest participation based on mutual funds 58

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 11 255
Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(a) where s. 212(13.1)(a) does not apply, it may be possible to consider a Canadian partner to be an interest payer 213

19 February 2003 Internal T.I. 2002-0125767 - STRONG CURRENCY BORROWINGS

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) 40
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest acceptable to link to stock index or price of shares of dissimilar corporation 100

13 July 2001 Internal T.I. 2000-005101 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 November 2000 External T.I. 2000-005097 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest link to FX fluctuation acceptable 118

24 November 1995 T.I. 950860 (C.T.O. "Withholding Tax on Prescribed Debt Obligations")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 July 1994 Internal T.I. 7-933455 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 C.R. - Q. 31

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IC-77-16R4 "Non-Resident Income Tax", 11 May 1992, para. 21

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1173)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

27 March 1990 T.I. AC74543 [guaranteed interest received as interest]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Raj Juneja, "Taxation of equity derivatives", 2015 CTF Annual Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wilson, "Selected Canadian Withholding Tax Issues", 1996 Cross-Border Taxation Issues and Developments, International Fiscal Association, p. 233

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subparagraph 212(1)(b)(i)

Administrative Policy

3 December 1992 T.I. 921655 (C.T.O. "Factoring Accounts Receivable Whether Sale or Loan"; Tax Window, No. 26, p. 5, ¶2315)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) 51

Articles

Subparagraph 212(1)(b)(ii)

See Also

Munich Reinsurance Co. (Canada Branch) v. The Queen, 2000 DTC 2009 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Moran v. Pappas (1997), 34 OR (3d) 251 (Ont. Ct. (G.D.))

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

R. v. Eldorado Nuclear Ltd.; R. v. Uranium Canada Ltd. (1983), 4 DLR (4th) 193, [1983] 2 S.C.R. 551

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Sydney Steel Corp v. A.L.E. & C. Ltd. (1983), 148 DLR (3d) 348 (N.S. C.A.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Re Canada Dairies Corp. Ltd. (1981), 131 DLR (3D) 605 (Ont. S.C.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

R. v. Ontario Relations Board, Ex. P. Ontario Housing Corp. (1971), 19 DLR (3d) 47 (Ont HC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

29 August 1995 Ruling 950632 (C.T.O. "Similar Obligations in 212(1)(b)(ii)(C)(II))

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 C.R. - Q.40

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

14 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 30, ¶1090)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Clause 212(1)(b)(i)(C)

Administrative Policy

16 November 2000 External T.I. 2000-005097 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Clause 212(1)(b)(iii)(C)

Cases

Munich Reinsurance Co. v. The Queen, 96 DTC 6185 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Clause 212(1)(b)(iii)(D)

Administrative Policy

2005 Ruling 2005-0139661R3 - Withholding Index-Linked Notes

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-360R2 "Interest Payable in a Foreign Currency"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Wilkie, "Structuring International Debt Issues: A Canadian Perspective", Canadian Tax Journal, January/February 1987, p. 1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Clause 212(1)(b)(iii)(E)

Cases

Kinguk Trawl Inc. v. Canada, 2003 DTC 5168, 2003 FCA 85

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Cutlers Guild Ltd. v. The Queen, 81 DTC 5093, [1981] CTC 115 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Kinguk Trawl Inc. v. The Queen, 2003 DTC 1524, 2003 TCC 842

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subparagraph 212(1)(b)(vii)

Cases

General Electric Capital Equipment Finance Inc. v. Canada, 2002 DTC 6734, 2001 FCA 392

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition changes to 3 of the 4 fundamental attributes of debt produced new debt 222

See Also

Lixo Investments Ltd. v. The Queen, 97 DTC 1030 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Carma Developers Ltd. v. The Queen, 96 DTC 1798 (TCC), briefly aff'd 96 DTC 6569 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2007 Ruling 2006-0218931R3 - Material Adverse Clause and Withholding Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2006 Ruling 2006-0211781R3 - Withholding Tax Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.3) on-loan by special purpose sub in ordinary course 58

2006 Ruling 2006-0195501R3 - Withholding Tax Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2006 Ruling 2006-0191881R3 - Witholding Tax Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

26 July 2005 External T.I. 2005-0134621E5 - Withholding Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) variable interest tracked creditworthiness 97
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest variable interest tracked creditworthiness, not profitability 97

2005 Ruling 2005-0124081R3 - Withholding Tax Exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2005 Ruling 2005-0133561R3 - withholding tax exemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2005 Ruling 2005-0119091R3 - Withholding tax; interest

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2005 Ruling 2004-009474 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Draft GST/HST Policy Statement "Agreements and Novation"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2004 Ruling 2004-009475 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 57

2004 Ruling 2004-009359 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2004 Ruling 2004-009273 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Income Tax Technical News, No. 30, 21 May 2004

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2003 Ruling 2003-03924 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 99

17 June 2003 External T.I. 2002-017845 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2002 Ruling 2002-016727 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 July 2002 External T.I. 2002-012218 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 July 2002 External T.I. 2001-008461 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2002 Ruling 2000/002948

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) stock index link 100
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest acceptable to link to stock index or price of shares of dissimilar corporation 100

17 September 2001 External T.I. 2001-0087185 - EVENT OF FAILURE OR DEFAULT

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 December 2001 External T.I. 2001-0111455 - WITHHOLDING TAX EXEMPTION INTEREST

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 May 2001 Ruling 2000-006062

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 January 2001 External T.I. 2000-000783 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

6 March 2000 External T.I. 1999-001355 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2000 Ruling 2000-0035043 - XXXXXXXXXX

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

15 June 1999 T.I. 50990303 [partnership entity for arm's length purposes]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 October 1999 Ruling 981707 [discount treated as interest when paid]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1997 IFA Round Table, Q. 5, No. 9713180

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1996 Ruling 3-962985 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 September 1998 Technical Interpretation 980737

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

21 July 1999 External T.I. 5-991545 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 March 1999 Technical Interpretation 982412

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Income Tax Technical News, No. 15, "The Tax Consequences of the Adoption of the 'Euro' Currency"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1998 Ruling 981339 [requirement to apply remaining asset sales proceeds]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Income Tax Technical News, No. 11, Sept. 30, 1997

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 September 1997 T.I. 9721405 [notice by issuer before convertible]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Income Tax Technical News, No. 9, 10 February 1997

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1997 Ruling 972356 [change of control cured with offer to repurchase]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1997 Ruling 970220

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1996 Ruling 3-962985 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) de facto change of control 55

1996 TEI Round Table, Part VII, Q. B., 9640070

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1996 Ruling 961368

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9.1) 62

18 January 1996 T.I. 953004 (C.T.O. "Commodity Reference in Paying Interest")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1996 Corporate Management Tax Conference Round Table, Q. 8

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.2) 74

1996 Ruling 962319 (C.T.O. "Withholding Tax on Interest")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

25 August 1995 T.I. 951733 (C.T.O. "Convertible Debentures with Anti-Dilution Clause")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 December 1993 T.I. 933305 (C.T.O. "Withholding Tax Exemption")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 C.M.TC - Q. 8

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 C.M.TC - Q. 7

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

93 C.M.TC - Q. 6

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.M.TC - Q. 13

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 C.R. - Q. 50

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 C.R. - Q. 17

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 August 1991 Memorandum (Tax Window, No. 8, p. 23, ¶1434)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

19 August 1991 T.I. (Tax Window, No. 8, p. 22, ¶1431)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 August 1991 T.I. (Tax Window, No. 7, p. 22, ¶1391)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

29 July 1991 T.I. (C.T.O. Fax Service Doc. No. 305; Tax Window, No. 7, p. 12, ¶1374)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 June 1991 T.I. (Tax Window, No. 4, p. 23, ¶1289)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 5, ¶1038)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(4) 18

25 January 1990 T.I. 5-8575

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 January 1990 T.I. (June 1990 Access Letter, ¶1280)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.R. - Q. 1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.R. - Q. 2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.R. - Q. 3

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 56

88 C.R. - "Finance and Leasing" - "Withholding Tax"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q. 2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

86 C.R. - Q. 11

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

86 C.R. - Q. 12

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

84 C.R. - Q. 38

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

84 C.R. - Q. 60

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

ATR-69, dated April 20, 1995

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

ATR-49

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-361R2 "Exemption from Tax on Interest Payments to Non-residents"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Read, "Technical Matters", 83 C.R., p. 783

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Robert A. Kopstein, Janette Y. Pantry, "Subparagraph 212(1)(b)(vii) Withholding Tax Exemption", 2005 Conference Report, c. 15.

Julie Colden, "Implications of Imperial Oil", Canadian Current Tax, Vol. 15, No. 3, December 2004, p. 21.

Jack A. Silverson, "The New Trust Proposals in Section 212(1)(b)(vii)", Corporate Finance, Vol. VII, No. 2, 1999, p. 615.

Smith, "Recent Transactions: Debt", 1993 Conference Report, C. 19

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Richardson, "European Currency Unit: A Currency for All Seasons", Corporate Finance, Vo. 1, No. 2, 1992, p. 43

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wilkie, "Issues Impacting on Exposure to Canadian Withholding Tax", Corporate Finance, Vol. 1, No. 1, 1992, p. 17.

Richardson, "Current Developments in Debt Financing: A Canadian Tax Perspective", 1988 Conference Report, C.22: Discussion of "poison puts".

Hansen, Richardson, "How Canadian Issuers Use Short-term Instruments", International Financial Law Review, February 1987, page 11

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wilkie, "Structuring International Debt Issues: A Canadian Perspective", Canadian Tax Journal, January-February 1987, page 1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Couzin, "Canada: Withholding Tax and Interest", Tax Management International Journal, January 1982, page 14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Loveland, "Income Tax Impediments to Foreign Investment in Canada", 1982 Conference Report, page 666

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 212(1)(c) - Estate or trust income

Administrative Policy

2014 Ruling 2013-0509431R3 - Part XIII tax and distributions from a trust

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 22 distributions to U.S. residents funded out of ROC payments and cross-border interest 265

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(11) redistribution of capital dividend subject to Part XIII tax 184

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(11) allocation of capital dividend between estate duties and NR distribution 125

July 1990 Memorandum

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) 32