Section 120

Subsection 120(1) - Income not earned in a province

Administrative Policy

9 July 2021 Internal T.I. 2021-0893981I7 - CERB received by non-residents

Regarding the treatment of payments (“CERB Payments”) made pursuant to the Canada Emergency Response Benefit Act (the “CERB Act”) to an...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 15 Other Income Art. accords Canada full right to tax CERB payments 225
Tax Topics - Treaties - Income Tax Conventions - Article 24 elimination of double taxation Art. addresses relief for taxation by Treaty partner of CERB payments 182

8 October 2014 Internal T.I. 2014-0539571I7 - NL tax vs Non-Res Surtax

Is employment income earned by a non-resident individual working in the Newfoundland offshore area (NOA) subject to provincial tax or the surtax...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 2602 - Reg. 2602(1) Nfld. Offshore employment income 71

25 July 2014 Internal T.I. 2013-0513641I7 - Deemed resident trust under subsection 94(3)

The Estate of a Canadian resident, with two non-resident beneficiaries and a non-resident liquidator was deemed to be resident in Canada as...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.01) meaning of "maximum amount...deductible" 168
Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(g) required Part XIII withholding treated like Part I instalment 151

S5-F1-C1 - Determining an Individual’s Residence Status

"An individual who is resident in more than one province on December 31 of a particular tax year will be considered to be resident only in the...

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Articles

Kevyn Nightingale, Amir Pourzakikhani, "A Federal Permanent Establishment, But Not a Provincial One", Tax Topics, Wolters Kluwer, November 3, 2016, No. 2330, p. 1

U.S. resident with Cdn Services PE only (pp. 1-2)

We recently dealt with a situation where a non-resident individual taxpayer had a Permanent...

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 4 115

Subsection 120(2)

Administrative Policy

4 June 2003 Internal T.I. 2003-0006967 F - Province de résidence d'une fiducie

A trust resident in Quebec avoided tax by making the election under s. 104(13.1) to be deemed to retain its income (notwithstanding its actual...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) Thibodeau applied to find that trust with Quebec trustee therefore was resident in Quebec 162
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit scheme generating Quebec abatement without payment of any Quebec tax did not result in a “tax benefit” 146
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2)(a)(i) inapplicable re settlor being beneficiary of trust beneficiary’s estate/ s. 75(2)(b) inapplicable re power of settlor to replace trustees 303

Subsection 120(4) - Definitions

Administrative Policy

3 December 2003 External T.I. 2003-003998

A trust whose beneficiaries are minor children of the shareholders of Corporation A (and who are assumed to be "specified individuals") is...

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