Subsection 115(1) - Non-resident’s taxable income in Canada
Paragraph 115(1)(a)
Subparagraph 115(1)(a)(i)
Cases
Hurd v. The Queen, 81 DTC 5140, [1981] CTC 209 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(e) - Subparagraph 115(2)(e)(i) | 9 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(4) | 93 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | meaning of exchange | 29 |
See Also
Blank v. Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | phantom profit participation unit amounts not income until paid by employer rather than when due | 700 |
| Tax Topics - General Concepts - Payment & Receipt | payments under phantom units not received when they vested | 308 |
Mullen v. The Queen, 2012 DTC 1154 [at 3358], 2012 TCC 139 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | non-residence claim was implausible | 195 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | superficial attempt to change residence | 195 |
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | 223 |
Price v. Canada, 2013 DTC 5024 [at 5615], 2012 FCA 332, aff'g 2011 DTC 1334 [at 1879], 2011 TCC 449
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Sutcliffe v. The Queen, 2006 DTC 2076, 2005 TCC 812
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | 91 |
Administrative Policy
21 February 2018 External T.I. 2017-0702061E5 - RCA contributions and taxable inc earned in Canada
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(m.2) | no deduction permitted where plan provided only for a lump sum payment or where it was excluded from SDA treatment by para. (j) (re athletes) | 195 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(ii) | s. 6(1)(a)(i) exclusion applied first before s. 4 allocation of income between Canada and U.S. | 144 |
16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(4) | non-resident's provision of crew and aircraft to Canadian airline | 140 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Traffic | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | Reg. 102 withholding or waiver notwithstanding Treaty exemption | 162 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | U.K company's provision of crew to Canadian airline/Reg. 102 withholding or waiver notwithstanding Treaty exemption | 285 |
S5-F2-C1 - Foreign Tax Credit
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10 December 2012 External T.I. 2011-0429721E5 F - OETC - Employee stock options benefits
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 122.3 - Subsection 122.3(1) - Paragraph 122.3(1)(d) | s. 7(1)(a) benefit apportioned based on Canadian and overseas duties performed - generally in year options issued | 150 |
25 September 2012 B.C. Canadian Tax Foundation Roundtable, 2012-0459411C6 - Allocation of cross-border employee stock options
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6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | employer reimburser of stock option benefit amount subject to withholding obligation | 340 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | U.S. subs qualifies as payer of (therefore exempt) stock option benefit/domestic v. Treaty method | 394 |
7 May 2009 External T.I. 2008-0276181E5 - Stock Option Benefits
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4 December 2003 External T.I. 2001-01177 -
19 January 2001 External T.I. 2000-005840 -
28 May 1996 TI 9601625
1996 Ruling 962639
2 December 1993 T.I. 933330 (C.T.O. "Non-Resident Exercise Stock Option (4093-U5-100-15)"
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | 214 |
13 June 1991 T.I. (Tax Window, No. 4, p. 28, ¶1299)
12 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 18, ¶1015)
81 C.R. - Q.56
IT-420R3 "Non-Residents - Income Earned in Canada"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 0 |
IT-168R3 "Athletes and Players Employed by Football, Hockey and Similar Clubs" under "Non-Residents"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(a) | 0 |
Articles
Tobias, "Taxing Benefits Realized by Former Canadian Residents", Taxation of Executive Compensation and Retirement, March 1994, p. 889
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(4) | 69 |
Finley, "Non-Resident Directors' Fees May Be Subject to Withholding in Canada", Taxation of Executive Compensation and Retirement, October 1990, p. 348
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 101 | 65 |
Subparagraph 115(1)(a)(ii)
Cases
Inter-Leasing, Inc. v. Ontario (Revenue), 2014 ONCA 575
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|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | underlying rationale for exempting property income was no broader than the text | 383 |
See Also
Commissioner of Taxation v Resource Capital Fund IV LP Commissioner of Taxation v Resource Capital Fund IV LP, [2019] FCAFC 51
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | assessment must bring to the attention of the assessed person that it has been assessed to tax | 244 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) | mine assets included processing operations | 412 |
Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | private equity fund LP with 5-year holding objective realized share gain on income account | 167 |
| Tax Topics - Treaties - Income Tax Conventions - Article 3 | each U.S.-resident partner of a Caymans PE LP carried on a U.S. “enterprise” | 222 |
| Tax Topics | 386 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | exclusion in Art. 13 of Aust.-U.S. Treaty for real property dispositions extended to shares of Australian holding company holding mining leases through grandchild | |
| Tax Topics - General Concepts - Stare Decisis | lower court not bound by a point of law that was assumed rather than examined by a higher court | 272 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | assessment of partnership was assessment of partners | 83 |
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | Art. 6 extends common law meaning of real property | 180 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d) | shares of lithium mining and processing company were derived principally from the processing rather than mining operation and, thus, were not taxable Australian real property | 500 |
| Tax Topics - Income Tax Act - Section 218.3 - Subsection 218.3(1) - Canadian Property Mutual Fund Investment | shares of Australian mining company were primarily attributable to the processing rather than mining operations | 140 |
| Tax Topics - General Concepts - Fair Market Value - Other | processing assets of mining company were more valuable than its mining assets | 234 |
Maya Forestales S.A. c. La Reine, 2005 DTC 514, 2005 TCC 66, aff'd 2008 DTC 6100, 2006 FCA 35
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|---|---|---|
| Tax Topics - Income Tax Act - Section 253 - Paragraph 253(b) | 119 |
Commissioner of Inland Revenue v. Kwong Myle Services Ltd. (2004), 7 ITLR 239 (HK CFA)
Twentieth Century Fox Film Corp. v. The Queen, 85 DTC 5513, [1985] 2 CTC 328 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 802 | 170 | |
| Tax Topics - Income Tax Regulations - Regulation 805 | film revenues were reasonably attributable to a Canadian distributorship business notwithstanding they were also attributable to U.S. movie production | 187 |
Yates v. GCA International Ltd., [1991] BTC 107 (Ch. D.)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 178 |
CIR v. Hang Seng Bank Ltd., [1990] BTC 482 (PC)
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|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | 47 |
Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221
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|---|---|---|
| Tax Topics - General Concepts - Evidence | 202 | |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | 203 |
United Geophysical Co. of Canada v. MNR, 61 DTC 1099 (Ex Ct)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | company's business not carried on as agent for shareholder | 148 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | "rent" can be for personalty | 100 |
Commissioner for Inland Revenue v. Nell (1961), 3 S.A. 774 (A.D.)
International Harvester Co. of Canada, Ltd. v. Provincial Tax Commission, [1949] A.C. 36 (PC)
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| Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(3) | 119 |
Federal Commissioner of Taxation v. United Aircraft Corp. (1943), 7 A.T.D. 318 (HC)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 39 |
Administrative Policy
7 June 2017 CPTS Roundtable, 2017-0695131C6
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|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | Q.1 - Daishowa extends beyond reforestation and reclamation obligations only on a case-by-case basis | 199 |
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Canadian Resource Property - Paragraph (d) | Q.2 - a Canadian resource royalty interest requires a right to “take production” | 129 |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | Q.3 - Canada-U.K. Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them | 185 |
| Tax Topics - Income Tax Regulations - Regulation 1101 - Subsection 1101(1) | Q.5 - normal course dispositions of oil and gas properties generally are not of a separate business | 123 |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) | Q.5 - application of Scales test to determining whether there is a separate business | 205 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 26 | Q.7 - refinery catalysts are Class 26 property | 81 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 49 | Q.8 - taxpayers generally have the documentary evidence on hand to allocate costs between pipelines and pipeline appendages | 111 |
19 June 2015 External T.I. 2013-0475751E5 - Withholding Tax on Royalty Payments
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5 February 2014 External T.I. 2012-0466671E5 - Non-resident source withholdings
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S5-F2-C1 - Foreign Tax Credit
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11 January 2001 Internal T.I. 2000-0001017 - Sourcing of income & foreign tax credit
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(2) | 113 |
2005 Ruling 2004-0094821R3 - Carrying on Business in Canada
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2004 Ruling 2004-008266 -
19 April 2000 External T.I. 1999-001100 -
1999 Ruling 992060
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|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 38 |
1997 Ruling 970492
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|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 52 |
1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)
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| Tax Topics - Treaties - Income Tax Conventions - Article 5 | 30 |
8 July 1992 T.I. 921814 (March 1993 Access Letter, p. 87, ¶C248-129)
Articles
Nathan Boidman, "How Will Revised Sourcing Rules Affect Sales of U.S.-Made Goods Abroad?", Tax Notes International, 10 February 2020, p. 655
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 7 | 375 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 24 | 482 |
Jinyan Li, "Rethinking Canada's Source Rules In The Age Of Electronic Commerce: Part I", 1999 Canadian Tax Journal, Vol. 47, No. 5, p. 1077.
Constantine Kyres, "Carrying on Business in Canada", 1995 Canadian Tax Journal, Vol. 45, No. 5, p. 1629.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 0 | |
| Tax Topics - Income Tax Act - Section 253 | 0 |
Subparagraph 115(1)(a)(iii.1)
Administrative Policy
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.4 - Subsection 66.4(5) - F | FMV addition and subtraction where drilling rights are granted for royalty | 137 |
| Tax Topics - Income Tax Regulations - Regulation 805 | application to resource royalties | 235 |
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | non-application of Art. 12 of US Treaty to resource royalties | 132 |
| Tax Topics - Treaties - Income Tax Conventions - Article 6 | negative CCDE gain from grant of oil and gas royalty not exempt under US Treaty | 166 |
Subparagraph 115(1)(a)(iii.2)
Paragraph 115(1)(d)
Paragraph 115(1)(e)
See Also
Matlas, S.A. v. The Queen, 94 DTC 1591 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(f) | 42 |
Administrative Policy
Paragraph 115(1)(f)
See Also
Delancy v. The Queen, 2004 DTC 2907, 2004 TCC 465 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h) | 64 |
Matlas, S.A. v. The Queen, 94 DTC 1591 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(e) | 100 |
Subparagraph 115(1)(b)(ii)
See Also
Pampered Chef, Canada Corp. v. CBSA, [2008] ETC 4514 (CITT)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Customs Act - 2.1 | 95 |
Subsection 115(2) - Idem [Non-resident’s taxable income in Canada]
Paragraph 115(2)(c)
Cases
Administrative Policy
26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | employee long-term disability payments: remuneration under ITA; pension under Cda-U.S. Convention | 206 |
| Tax Topics - Treaties - Income Tax Conventions - Article 18 | employee long-term disability payments: remuneration under ITA; pension under Cda-U.S. Convention | 251 |
Paragraph 115(2)(e)
Subparagraph 115(2)(e)(i)
Cases
Hale v. The Queen, 90 DTC 6481 (FCTD), aff'd 92 DTC 6473 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 127 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | 102 |
Hurd v. The Queen, 81 DTC 5140, [1981] CTC 209 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | 30 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(4) | 93 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | meaning of exchange | 29 |
Administrative Policy
20 March 2015 External T.I. 2014-0534301E5 - Canadian Withholding Tax on Retiring Allowance
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(j.1) | retiring allowance paid to non-resident for loss of non-resident employment | 145 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | retiring allowance paid to French individual for loss of non-resident employment | 71 |
| Tax Topics - Treaties - Income Tax Conventions - Article 22 | retiring allowance paid to French individual for loss of non-resident employment | 71 |
Subparagraph 115(2)(b)(ii)
Subsection 115(2.1)
Administrative Policy
27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment
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|---|---|---|
| Tax Topics - Income Tax Act - Section 216.1 - Subsection 216.1(1) | late filing under s. 216.1 not accommodated | 208 |
| Tax Topics - Treaties - Income Tax Conventions - Article 16 | Art. 16 of US Treaty permits gross withholding taxation even if PE | 166 |
Subsection 115(3)
Administrative Policy
7 September 2016 External T.I. 2014-0559751E5 - Subsection 115(3)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | comparison of Treaty and domestic method for pilot income on annual basis | 107 |
Subsection 115(4) - Non-resident’s income from Canadian resource property
Administrative Policy
16 June 2014 External T.I. 2013-0515431E5 - International traffic and airline enterprise
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | application of Sutcliffe/Price allocation approach were s. 115(3) not applicable | 140 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Traffic | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c) | non-resident's provision of crew and aircraft to Canadian airline | 103 |
| Tax Topics - Income Tax Regulations - Regulation 102 - Subsection 102(1) | Reg. 102 withholding or waiver notwithstanding Treaty exemption | 162 |
| Tax Topics - Treaties - Income Tax Conventions - Article 15 | U.K company's provision of crew to Canadian airline/Reg. 102 withholding or waiver notwithstanding Treaty exemption | 285 |