See Also
Agence du revenu du Québec v. Cristofaro, 2021 QCCA 1025
The taxpayer, who was an Ontario resident, paid taxes in Quebec as a result of his professional firm carrying on a portion of its practice through...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Territorial Limits | Oceanspan applied to preclude credit transfer from a non-taxpayer | 227 |
Cristofaro v. Agence du revenu du Québec, 2020 QCCQ 1461, rev'd 2021 QCCA 1025
The taxpayer, who was an Ontario resident, paid taxes in several provinces including Quebec as a result of his professional firm’s business...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer | individual with no residence or source of income in Quebec nonetheless might be liable for Quebec tax | 372 |
Administrative Policy
15 January 2004 Internal T.I. 2003-0026827 - Non-resident & Tuition & Educations credits
A Canadian-resident father is claiming tuition and education tax credits transferred under s. 118.9 from his non-resident daughter who has been...
Subsection 118.9(4)
Administrative Policy
12 April 1995 External T.I. 9417135 - CANADIAN MUTUAL FUND TRUST-NON-RESIDENT
"All or substantially all" is considered to be 90%.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 104 - Subsection 104(21) | capital gains distributed to non-resident MFT beneficiaries not taxable | 23 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(11) | 23 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 22 | 27 |