Section 116

Table of Contents

Section 116
Subsection 116(1) - Disposition by non-resident person of certain property
See Also(1)
Administrative Policy(16)
Articles(3)
Subsection 116(2) - Certificate in respect of proposed disposition
Cases(2)
Administrative Policy(10)
Subsection 116(3) - Notice to Minister
See Also(2)
Administrative Policy(3)
Subsection 116(4) - Certificate in respect of property disposed of
See Also(1)
Administrative Policy(2)
Subsection 116(5) - Liability of purchaser
Cases(2)
See Also(5)
Administrative Policy(17)
Articles(2)
Paragraph 116(5)(a)
Administrative Policy(1)
Subsection 116(5.2) - Certificates for dispositions
Administrative Policy(2)
Subsection 116(5.3) - Liability of purchaser in certain cases
Administrative Policy(5)
Subsection 116(5.01) - Treaty-protected property
Articles(3)
Subsection 116(6.1) - Treaty-exempt property
Administrative Policy(2)

Subsection 116(1) - Disposition by non-resident person of certain property

See Also

Gambino v. The Queen, 2009 DTC 4, 2008 TCC 601 (Informal Procedure)

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Administrative Policy

Guidance on international income tax issues raised by the COVID-19 crisis, CRA Webpage 31 March 2021

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2020 Ruling 2019-0799981R3 - Disposition – Reclassification and Stock Split

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition a simultaneous consolidation of 7 identical series of common shares into 1 series, and a stock split, did not effect a disposition 285

21 November 2017 CTF Roundtable Q. 14, 2017-0724241C6 - Section 116 procedures for tax-deferred dispositions on foreign mergers

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(8.5) requirements for letter election 89

S4-F7-C1 - Amalgamations of Canadian Corporations

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Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 113
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 132
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 157
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 103
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 88
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 172
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) related party, majority and 50% group exceptions 495
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 62
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 113
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 165
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 87
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 66
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 109
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 120
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 55
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 297
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 758
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 113
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 149
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 64
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 139
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 169
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 44
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 346
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 189
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 281
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 191
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 230
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 122
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 62
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 137
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 467
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 371
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 327
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 106
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3) 136
Tax Topics - Income Tax Act - Section 22 - Subsection 22(1) 179

4 December 2013 Internal T.I. 2013-0489051I7 - Personal-Use-Property & Article XIII(9)

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Tax Topics - Treaties - Income Tax Conventions - Article 13 personal-use land and building are one property 133

19 March 2013 Internal T.I. 2010-0385931I7 - Taxable Canadian property and Partnerships

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (e) TCP rules not applying to foreign partners of partnership 278
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) partnership TCP gain but not TCP status attributed to partners 88

4 January 2013 External T.I. 2012-0448681E5 - s. 116 req. of NR-estates per draft NRT legis.

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29 March 2012 External T.I. 2010-0385771E5 - Taxation of an Estate

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3 December 2012 External T.I. 2012-0457741E5 - Disposition of taxable Canadian property

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition non s. 87 amalgamation 155

17 May 2012 IFA Roundtable, 2012-0444081C6 - 2012 IFA Seminar - Question 4

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11 October 2012 External T.I. 2011-0429021E5 - Administrative Position subsections 87(4)/116

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8 October 2010 Roundtable, 2010-0373401C6 F - Fiducies et ajout d'un bénéficiaire

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition court-approved addition of a beneficiary will result either in a part disposition of trust interests, or a constructive dissolution and resettlement of the discretionary trust 325

9 February 2010 Internal T.I. 2009-0333571I7 F - Paragraphe 7(1.5) - contrepartie reçue

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.5) s. 7(1.5) rollover where employees exchanged specific s. 7(1.1) shares for shares of grandparent, even though they also received cash and PUC distribution 454
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(j) ACB increased by s. 7(1) benefit that had not yet been triggered due to s. 7(1.5) rollover 276
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) non-resident ex-employees will be required to recognize s. 7 benefit deferred by s. 7(1.5) when they dispose of the shares acquired in exchange 148

24 February 2003 External T.I. 2002-014995

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition 95

1993 A.P.F.F. Round Table, Q. 25

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Tax Topics - Treaties - Income Tax Conventions - Article 13 43

24 September 1992 T.I. (Tax Window, No. 24, p. 13, ¶2181)

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Articles

Steve Suarez, Maire-Eve Gosselin, "Canada's Section 116 System for Nonresident Vendors of Taxable Canadian Property", Tax Notes International,9 April 2012, p. 175

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Kevin Scott, S. Sebastian Elawny, "Estate Distributions to Non-Residents", CCH Tax Topics, No. 1911, 23 October 2008, p. 1.

Jack Bernstein, "Why Canada Should End the Roadblock to Foreign Private Equity", Tax Notes International, 46/9 May 28, 2007.

Subsection 116(2) - Certificate in respect of proposed disposition

Cases

MNR v. Morris, 2010 DTC 5013 [at 6575]

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Morris v. Canada (National Revenue), 2009 FC 434

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Tax Topics - Treaties - Income Tax Conventions - Article 4 104

Administrative Policy

25 June 2014 External T.I. 2012-0465221E5 - Trust distributions to non-residents

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1992 A.P.F.F. Annual Conference, Q. 23 (January - February 1993 Access Letter, p. 59)

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1992 A.P.F.F. Annual Conference, Q. 13 (January - February 1993 Access Letter, p. 55)

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90 C.P.T.J. - Q.28

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87 C.R. - Q.79

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Tax Topics - Income Tax Act - Section 48 - Subsection 48(1) 25

87 C.R. - Q.87

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87 C.R. - Q.90

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86 C.R. - Q.89

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IT-150R2 "Acquisition from a Non-Resident of Certain Property on Death or Mortgage Foreclosure or by Virtue of a Deemed Disposition" /p>

IC 72-17R4 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada - Section 116"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition 27

Subsection 116(3) - Notice to Minister

See Also

Lipson v. The Queen, 2012 DTC 1064 [at 2796], 2012 TCC 20

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Serge Côté Family Trust v. Canada (Attorney General), 2010 DTC 5071 [at 6798], 2009 FC 698

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Administrative Policy

30 May 2018 External T.I. 2017-0717981E5 - Clearance certificate for a non-resident

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Tax Topics - Income Tax Act - Section 159 - Subsection 159(2) executors of non-resident estates that could have Canadian tax liabilities to apply for a clearance certificate 171

17 February 2014 Internal T.I. 2013-0498121I7 - Follow up to XXXXXXXXXX

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Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) diplomatic exemption/discretion if property sold at loss 129

25 September 2013 External T.I. 2013-0485751E5 F - Rescinding 45(2) election by a non-resident

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(2) deemed dispositin on 1st day of revocation year triggers s. 116(3) filing 151

Subsection 116(4) - Certificate in respect of property disposed of

See Also

Corporation A.A.A. S.A. v. MNR, 92 DTC 1805, [1992] 1 CTC 2476 (TCC)

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Administrative Policy

17 February 2017 External T.I. 2015-0602781E5 - Disposition of farm property by a non-resident

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Tax Topics - Treaties - Income Tax Conventions - Article 13 shares of Cdn farm are excluded from immovable property under Canada-Germany Treaty 144
Tax Topics - Income Tax Act - Section 116 - Subsection 116(6.1) failure to file notice within 30 days 150

8 May 1995 External T.I. 9504015 - MEANING OF TAX CND PTY (SHARES HELD AS INVENTORY)

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Subsection 116(5) - Liability of purchaser

Cases

Coast Capital Savings Credit Union v. Canada, 2016 FCA 181

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Words and Phrases
cost
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Tax Topics - General Concepts - Sham deceit of taxpayer was irrelevant to assessment – so that “sham” also was irrelevant 282
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base no bifurcation of inflated purchase price between FMV cost and benefit conferral 142

Olympia Trust Company v. Canada, 2015 FCA 279

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) fictitious s. 104(2) trust is not the purchaser 118
Tax Topics - General Concepts - Evidence contract informed by surrounding circumstances 59

See Also

1074022 B.C. Ltd. v Li, 2020 BCSC 65

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Tax Topics - Income Tax Act - Section 164 - Subsection 164(1) CRA could be directed to pay an excess s. 116 remittance to the taxpayer’s secured creditors 351

Kau v. The Queen, 2018 TCC 156

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Scotia Mortgage Corporation v Gladu, 2017 BCSC 1182

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Tax Topics - Income Tax Act - Section 220 - Subsection 220(1) no jurisdiction to declare that a vendor was a Canadian resident for s. 116 purposes 265

Coast Capital Savings Credit Union v. The Queen, 2015 TCC 195, aff'd 2016 FCA 181

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Tax Topics - General Concepts - Sham sham may be pleaded only by the Minister 227

Olympia Trust Company v. The Queen, 2014 TCC 372, aff'd 2015 DTC 5134 [at 6411], 2015 FCA 279

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Tax Topics - General Concepts - Ownership RRSP trustee, not annuitant, was the "purchaser" 144

Administrative Policy

27 October 2020 CTF Roundtable Q. 4, 2020-0862451C6 - Sale of TCP by a partnership

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9 August 2017 External T.I. 2017-0709351E5 - Interaction between subsections 98(1) and 116(5)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(1) - Paragraph 98(1)(c) a negative ACB gain from a partnership interest that is TCP is not subject to s. 116 118

May 2016 Alberta CPA Roundtable, Q.14

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16 March 2015 Internal T.I. 2013-0479861I7 - Section 116 & forfeited deposits on real property

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) forfeited sale deposit was proceeds 79
Tax Topics - Income Tax Act - Section 248 - Subsection 248(4) forfeited sale deposit was proceeds of security interest rather than of tcp 264

2 June 2011 External T.I. 2011-0399501E5 - TCP distributed by N/R trust to N/R beneficiary

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

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12 June 2009 External T.I. 2008-0301701E5 - Redemption of shares

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21 September 2006 Internal T.I. 2006-0201651I7 - Disposition of Taxable Canadian Property ("TCP")

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28 November 2001 Internal T.I. 2001-0091247 - Employer Stock Opt. & Section 116116(5)

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6 February 1997 External T.I. 9626625 - SECTION 116 - JOINT TENANCY

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11 October 1996 T.I. 963371 (C.T.O. "Sec 116 Exercise of Power of Sale Non-Resident Mortgagee")

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24 May 1995 External T.I. 9501345 - SECTION 116 - POWER OF SALE

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5 April 1995 External T.I. 9431435 - FORECLOSURE AND 116(5)

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1 March 1995 External T.I. 5-940226 -

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October 1989 Revenue Canada Round Table - Q.16 (Jan. 90 Access Letter, ¶1075)

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88 C.R. - Q.6

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84 C.R. - Q.39

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Articles

Vivien Morgan, "CRA on Section 116", Canadian Tax Highlights, Vol. 17, No. 9, September, 2009, p. 9.

Gabrielle M.R. Richards, "Capital Financing by Non-Residents: Section 116 Obligations", Corporate Structures and Groups, Vol. VII, No. 3, 2002, p. 375

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) 36

Paragraph 116(5)(a)

Administrative Policy

25 August 2017 External T.I. 2017-0703351E5 - Paragraph 116(5)(a) - reasonable inquiry

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(5.3) statutory declaration sufficient if no negative markers 92

Subsection 116(5.2) - Certificates for dispositions

Administrative Policy

90 C.R. - Q59

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89 C.P.T.J. - Q2

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5.3) 46

Subsection 116(5.3) - Liability of purchaser in certain cases

Administrative Policy

25 August 2017 External T.I. 2017-0703351E5 - Paragraph 116(5)(a) - reasonable inquiry

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) - Paragraph 116(5)(a) in the absence of counter indicators, a statutory declaration of residence is sufficient 167

29 January 2013 External T.I. 2012-0470331E5 - S.116 - Qualified Business Exemption

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25 October 1993 External T.I. 9324605 - FORECLOSURE ACTION INSTITUTED BY MORTGAGEE (7354)

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89 C.P.T.J. - Q2

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5.2) 12

81 C.R. - Q.19

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Subsection 116(5.01) - Treaty-protected property

Articles

Steve Suarez, Maire-Eve Gosselin, "Canada's Section 116 System for Nonresident Vendors of Taxable Canadian Property", Tax Notes International,9 April 2012, p. 175

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Michael N. Kandev, Fred Purkey, "Practical Troubles With the Disposition of Canadian-Situs Property by Nonresidents of Canada", Practitoner's Corner, Tax Notes International, 12 September 2011, p. 807.

Rhonda Rudick, "No Section 116 Safe Harbour", Tax Topics, 12 May 2011, No. 2044, p. 1

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Subsection 116(6.1) - Treaty-exempt property

Administrative Policy

17 February 2017 External T.I. 2015-0602781E5 - Disposition of farm property by a non-resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 116 - Subsection 116(4) CRA may accept a T2062 showing deemed s. 73(4.1) rollover proceeds 297
Tax Topics - Treaties - Income Tax Conventions - Article 13 shares of Cdn farm are excluded from immovable property under Canada-Germany Treaty 144

2012 Ruling 2011-0429961R3 - Hydrocarbon & Immovable property: Canada-UK Treaty

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